OnLine Mortgage

(A Division of Access Business Consulting Services Inc.)

Policy On the Collection, Use and Disclosure Of Personal Information

“Privacy Policy”

1. Objective & Scope of Policy

OnLine Mortgage is committed to respecting your privacy and has prepared this Policy to inform you of our policy and practices concerning the collection, use and disclosure of Personal Information.

This Policy governs Personal Information collected from and about (i) individuals who are or may become Clients of OnLine Mortgage and (ii) individuals or organizations with whom OnLine Mortgage works with.

Using contractual or other arrangements, OnLine Mortgage shall ensure that agents, contractors or third party service providers, who may receive Personal Information in the course of providing services to OnLine Mortgage as part of our delivery of mortgage brokerage services, protect that Personal Information in a manner consistent with the principles articulated in this Policy.

This Policy does not cover aggregated data from which the identity of an individual cannot be determined. OnLine Mortgage retains the right to use aggregated data in any way that it determines appropriate.

In the event of questions about: (i) access to your Personal Information; (ii) OnLine Mortgage’s collection, use, management or disclosure of Personal Information; or (iii) this Policy; we have appointed the following person (our “Privacy Officer”) to be responsible for ensuring that the protection of your personal information is carried out in accordance with this Privacy Policy, please contact:

Paul Lioukras, President, onlinemortgage@rogers.com, 416-704-3310

2. The Collection, Use & Disclosure of Personal Information

"You" and "your" means the applicant and any joint applicant. "We", "our" and "us" means OnLine Mortgage.

You authorize us to collect personal information (including credit, employment and other financially-related information) about you, from you and from credit bureaus, credit reporting agencies, financial institutions, references you have provided to us and from persons who may have referred your mortgage business to us.

You acknowledge that the personal information collected from you and others may be used for the following purposes: (i) to determine your financial situation; (ii) to determine your initial and ongoing eligibility for mortgage services; (iii) to administer or service your mortgage; (iv) to arrange for and in connection with the financing of our mortgage business; (v) for post-closing customer care purposes, including servicing you at time of renewal; and (vi) as otherwise necessary for the provision of mortgage services.

You acknowledge that the personal information collected from you and others may be disclosed to the following people or organizations, for the following purposes: (i) to credit bureaus, credit reporting agencies, mortgage insurers and financial institutions to confirm your financial situation and your initial and ongoing eligibility for mortgage services; (ii) to persons retained to administer or service your mortgage for the purpose of such administration or servicing; (iii) to persons (or their permitted assignees) involved in the financing or securitizing, or facilitation of the financing or securitizing, of our mortgage business for the purpose of their providing or facilitating such financing or securitizing (which may include the administration or servicing of your mortgage by them or their agents); and (iv) to other persons as necessary for the provision of mortgage and related services to you.

Any contact or dealings that you may have with third parties using any personal information, including the delivery of and the payment for goods and services, and any other terms, conditions, warranties or representations associated with such dealings are solely between you and the third party. OnLine Mortgage shall not be responsible or liable in any way for any part of such dealings.

For the purposes of this Policy:

“Client” means an individual who may or has contacted OnLine Mortgage to arrange for mortgage financing or mortgage brokerage services.

"Personal Information" means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from such information.

Your provision of Personal Information to OnLine Mortgage means that you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Privacy Policy. If you do not agree with these terms, you are requested not to provide any Personal Information to OnLine Mortgage or a Broker or an Agent working with OnLine Mortgage. Unfortunately, certain services can only be offered if you provide Personal Information and consequently, if you choose not provide us with any required Personal Information, OnLine Mortgage may not be able to offer you those services.

This office only collects personal information necessary to effectively arrange mortgage financing, loans or lines of credit, market your financial requirements to lenders, and to otherwise provide professional and competent mortgage brokerage and related services to clients.

OnLine Mortgage, Brokers or Agents may use personal information for commission management purposes (e.g. commission financing, commission dispute resolution).

OnLine Mortgage’s use of Personal Information is limited to these purposes. OnLine Mortgage does not sell, trade, barter or exchange for consideration any Personal Information it has obtained. Unless permitted by law, no personal information is collected about an individual without first obtaining the consent of the individual to the collection, use and dissemination of that information.

Personal information will be collected, to the extent possible, directly from the individual concerned.

OnLine Mortgage does not knowingly collect Personal Information from anyone under the age of 18, especially children under 13, and does not use such information if OnLine Mortgage discovers that it is has been provided by a minor.

Personal Information may also be transferred to another company in the event of a change of ownership of all or part of OnLine Mortgage.

OnLine Mortgage may disclose Personal Information of Clients to organizations that perform services on its behalf. This will only be done if such organizations agree to use such information solely for the purposes of providing services to OnLine Mortgage and, with respect to that information, to act in a manner consistent with this Policy.

Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where OnLine Mortgage is obliged to disclose information without consent. Such circumstances may include:

• Where required by law or by order or requirement of a court, administrative agency or other governmental tribunal;
• Where OnLine Mortgage believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
• Where it is necessary to establish or collect monies owning to OnLine Mortgage;
• Where it is necessary to permit OnLine Mortgage to pursue available remedies or limit any damages that OnLine Mortgage may sustain;
• Where the information is public; or
• Where the information provided has been fraudulent or unlawfully provided.
• Where obliged or permitted to disclose information without consent, OnLine Mortgage will not disclose more information than is required.

3. Accuracy

OnLine Mortgage endeavours to ensure that any Personal Information provided by Clients and in its possession is as accurate, current and complete as necessary for the purposes for which OnLine Mortgage uses that data. Information contained in files that have been closed is not actively updated or maintained.

4. Retention

OnLine Mortgage retains Personal Information as long as OnLine Mortgage believes it is necessary to fulfil the purpose for which it was collected and Firm legal or business requirements.

5. Security

OnLine Mortgage endeavours to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information.

OnLine Mortgage further protects Personal Information by restricting access to it to those Employees and Contractors that the management of OnLine Mortgage has determined need to know that information in order that OnLine Mortgage may provide services to Clients.

7. Access to Personal information

OnLine Mortgage permits access to and review of Personal Information held by OnLine Mortgage about an individual by the individual concerned.

If an individual believes any Personal Information concerning that individual is not correct, that person may request an amendment of that information by sending a request to the person indicated in Section 1 of this Policy. OnLine Mortgage reserves the right not to change any Personal Information but will append any alternative text the individual concerned believes appropriate. Where not required to be retained by the Firm, an individual may also request that OnLine Mortgage delete an individual’s Personal Information from OnLine Mortgage’s system and records. However, due to constraints of computer technology and the fact that OnLine Mortgage backs up its systems, Personal Information may continue to reside in OnLine Mortgage’s systems after deletion. Individuals, therefore, should not expect that their Personal Information would be completely removed from OnLine Mortgage’s systems in response to an accepted request for deletion.

OnLine Mortgage reserves the right to decline access to Personal Information where the information requested:

• Would disclose the Personal Information of another individual or of a deceased individual;

• Would disclose business confidential information that may harm OnLine Mortgage or the competitive position of a third party;

• Is subject to solicitor-client or litigation privilege;

• Could reasonably result in: (i) serious harm to the treatment or recovery of the individual concerned; (ii) serious emotional harm to the individual or another individual; or (iii) serious bodily harm to another individual;

• May harm, or interfere with, law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions;

• Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information; or

• Does not exist, is not held, or cannot be found by OnLine Mortgage.

Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.

Where information will be disclosed, OnLine Mortgage will endeavor to provide the information in question within a reasonable time and no later than 30 days following the request.

OnLine Mortgage will not respond to repetitious or vexatious requests for access. In determining whether a request is repetitious or vexatious, it will consider such factors as the frequency with which information is amended, the purpose for which the information is used, and the nature of the information.

To guard against fraudulent requests for access, OnLine Mortgage will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections.

8. Amendment of Practices and This Policy

This statement is in effect as of January 1, 2004. OnLine Mortgage will from time to time review and revise its privacy practices and this Policy. In the event of any amendment, an appropriate notice will be communicated to Clients and others in an appropriate manner.

9. OnLine Privacy

When interacting with us through our web sites, there are three ways in which we may collect personal information that are unique to the Internet. 

Cookies

"Cookies" are pieces of information that may be placed on your computer by a web site for the purpose of facilitating and enhancing your communication and interaction with that web site.  Almost all web sites use cookies for these purposes.

We may use three different types of cookies on our web sites: persistent cookies, session cookies, and third-party cookies.  (Please refer to your browser's Help section for further information on controlling and setting cookies).

A persistent cookie remains on your hard drive for authentication purposes where the use of one of our web sites requires a username and password.  We may use a persistent cookie to save your username (only if you ask to remember your username on the computer you use to access our web site) so you don't have to re-enter it each time you visit one of our sites.  You may choose to reject persistent cookies and use your login password each time you visit a site, and the site will still function correctly.

A session cookie is temporary, only used during a single session on our web sites, and is automatically deleted at the end of your visit. We use session cookies (a) to customize your visit to our web sites and your experience, (b) to deliver content consistent with your stated interests and the manner in which you browse and/or use our web sites, and (c) for other purposes to make your visit more convenient.

At times, some of our third party advertisers or their ad serving and tracking providers may place cookies on your computer system when you select their ad banner and some of our content providers or partners may also place cookies on your computer system when you visit those portions of our web sites over which they have control.  We have no control over these third party cookies and we do not receive the data collected by those cookies.  The information that we receive from these unaffiliated third parties is only anonymous and non-personally identifiable information ("Aggregate Information").

You may stop or restrict the placement of cookies on your computer or flush them from your browser by adjusting your web browser preferences.  Depending on the web site, the rejection of session cookies may interfere with the functionality of the web site and in certain cases you may have to accept session cookies in order for the site to function at all.  If your browser does not differentiate between persistent and session cookies, then you my have to enable all cookies in order for our web sites to function properly.

We do not use cookies to retrieve information from your computer for purposes that are unrelated to the service being offered over the applicable web site or your interaction with that web site.

Internet Protocol Addresses

We may use your IP address (the number assigned to your computer when you use the Internet) to help diagnose problems with our server and to administer our web sites.  For our internal purposes, we gather date, time, browser type and IP address of all visitors to our site. We keep this information for system administration, for web server load balancing, to report Aggregate Information to our advertisers and for our internal security audit log.  We do not link IP addresses to personal information.  Your IP address may also be used to help identify you for the duration of a session and to gather broad, aggregate demographic information.  Your IP address will never be linked to any of your personal information unless you are in the process of making a purchase, in which case the link between this information will terminate upon your final purchase.

Clickstream

As you use the Internet, a trail of electronic information is left at each web site you visit. This information, which is sometimes referred to as "clickstream data," can be collected and stored by a web site server. Clickstream data can tell us the type of computer and browsing software you use, the address of the web site from which you linked to one of our web sites, and, in some instances, your e-mail address.  We may use clickstream data as a form of Aggregate Information (see above) to anonymously determine how much time visitors spend on our web site pages, how visitors navigate throughout our sites and how we may tailor our web pages to better meet the needs of visitors.  This information will only be used to improve our web sites. Any collection or use of clickstream data will be anonymous and aggregate, and will not contain any personal information.

Links To Third Party Sites

Our web sites may contain links to other third party web sites, and other third party web sites may reference or link to our web sites.  We are not responsible for the privacy practices, terms or the content of such other third party web sites and we advise you to check their privacy policies and terms as well.

Any dealings that you have with third parties using any linked site, including the delivery of and the payment for goods and services, and any other terms, conditions, warranties or representations associated with such dealings are solely between you and the third party. OnLine Mortgage shall not be responsible or liable in any way for any part of such dealings

Often, links to other websites are provided solely as pointers to information on topics that may be useful to the users of this website.

Security

The security of your personal information transmitted to and from us over the Internet is very important to us.  We attempt to provide for the secure transmission of your information from your computer to our servers and vice versa by utilizing encryption software.  However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and us will be free from unauthorized access by third parties, such as hackers and your use of our web sites demonstrates your assumption of this risk.

Periodic Changes to This Privacy Notice

Since the privacy standards set forth herein are subject to updates and other changes from time to time, please note that this Privacy Notice is subject to change at any time. In the event of any such changes, we will notify all of our customers of such changes in the manner and to the extent required by law.