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Privacy Policy

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. 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.

ACCOUNTABILITY

We have appointed a member of our senior management team as CMI’s Privacy Officer. The Privacy Officer is responsible for ensuring that our Privacy Policy is up to date. Our employees and representatives are informed about the importance of privacy and receive information periodically to update them about our Privacy Policy and related policies. Each employee and representative of CMI is responsible for the personal information under his or her control.

WHY DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect and use personal information for several reason. 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. It is used

• to verify your identity;
• to determine the suitability of our products and services;
• to evaluate your application for financing, particularly with respect to credit risk;
• to understand your financial needs and determine which financial products or related services may be of use to you and help meet your needs, and to offer those to you either ourselves or organizations with which we have strategic alliances;
• to share with third parties CMI may select and make arrangements with as its business associates for mortgage, credit and other insurance, for card services and for homeownership related products and services; those business associates may directly or through us determine eligibility for products and offer them 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.

CONSENT

Your consent is required before we may collect, use or disclose your personal information, except in special circumstances, such as legal and security situations. We accept any of the following as your consent for CMI’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 CMI 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 (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 address or telephone number listed below.

LIMITING COLLECTION, USE, DISCLOSURE AND RETENTION OF INFORMATION

The personal information about you which we collect will be limited to that which is necessary for the purposes we identified to you. Information will be collected by us only by fair and lawful means. 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. 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 CMI fulfilling its routine obligations and conducting its business in the ordinary course. This includes, for example, disclosure to third party lenders, rating agencies, consumer reporting agencies, partners, consultants, and suppliers to CMI (also known collectively as "service providers"). 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.

KEEPING YOUR INFORMATION ACCURATE

CMI endeavours to base its decisions on each customer’s accurate, complete and relevant personal information. We rely on you to disclose all material information and to inform us of any changes so we may update our files.

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.

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
• 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 reason for the refusal.

WEBSITE INFORMATION

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends and administer the site.

HOW WE USE COOKIES

An internet cookie is a small text file that a website stores on your internet browser and that can collect and store information. We use cookies to better understand how you use our websites, to make sure our ads and dynamic content are served correctly and to improve the performance of our websites. For example, a cookie may recall a set of preferences you have set for our website and record items that you have registered for. Storing cookies on your web browser allows us to present you with custom web pages and other content that are tuned with your preferences. If you are concerned about cookies, it is possible to turn them off in your web browser preferences. We note that if you turn cookies off, you will not have access to certain features on our sites that make your online experience more efficient and some of our services may not function properly. We may contract with third party service providers to assist us in better understanding our site visitors and record your browsing habits in order to improve our product and service offerings and customer service. Our website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our website and provides us with website analytics. These tracer tags are used to help us optimize and tailor our website for you and other future visitors to our website.

ANALYTICS

We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the website. These third parties may use cookies and other tracking technologies.

SOCIAL MEDIA

We may offer you the opportunity to engage with us or our content on or through third-party websites (such as LinkedIn or Facebook). When you engage with us or our content on or through these websites, you may allow us to have access to certain information associated with your account in accordance with your settings on the third party site (e.g., name, username, email address, profile picture) and we may have access to information about your interactions with our content.

THIRD PARTY LINKS

Our website may contain links to other sites that we do not own or operate. Also, links to our website may be featured on third party websites on which we advertise. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites and social media platforms have separate and independent privacy statements, notices and terms of use, pixels and cookies, which we recommend you read carefully. We do not have any control over such sites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

RESPECTING AND RESPONDING TO YOUR PRIVACY CONCERNS

This Policy is made available to the public in electronic form at www.xxx.ca. Updated versions of this Privacy Policy may be posted on CMI’s website at xxxx If you have any questions or concerns regarding your privacy or this Privacy Policy, you should direct them to CMI’s Privacy Officer at mailing or email address below.

CMI Privacy Officer
Address: privacy@thecmigroup.ca
Please be sure to include your name, address, preferred method of communication, the nature of your concerns and relevant details, including your past communications with us. If you have a complaint and it is justified, we will take the steps necessary to resolve the issue, including, if necessary, amending our Privacy Policy and procedures.

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