Last Updated: April 11, 2019.
PART A – COLLECTION OF PERSONAL INFORMATION
We may collect the Personal Information you disclose to us through your use of the Website as well as other information as set out below.
1. Information you Provide
Your voluntary disclosure of Personal Information may include, but is not limited to:
(a) basic personal information, including your name, contact information, marital status, living history, and income level;
(b) information, including passwords and other details about your subscriptions to third party sites, which may include social media sites;
(c) information about third parties who may be your beneficiaries or estate managers;
(d) information required to complete your mortgage application, including your credit history, desired mortgage goal, medical information, property, subject property, assets, education, employment information and social insurance numbers;
(e) information collected in a dispute resolution if applicable;
(f) information you provide when you engage with the Website for various purposes, including account openings, registration or submission of other information to us; and
(g) any feedback you provide regarding our products and services.
Collection of this Personal Information is necessary for us in order to execute upon your preferences.
2. Automatic Information
During your interaction with the Website, we may collect and store anonymous information (“Automatic Information”) about you as you engage with our Website and services. This information may be collected using various technologies including, without limitation, “Cookies” (meaning alphanumeric identifiers that are stored on your device with which you access our Services), Internet tags and navigational data. Some of this information is automatically transmitted to us through your browser, such as the URL that you just visited, the browser version that your computer uses, the pages of our website that you visit, the time spent on each page, the time and date of you visit and other statistics.
Please note that if your browser is not set to allow cookies, you may not have access to all areas or features of our Services.
In addition, we may use third party services such as Google Analytics and Intercom that collect, monitor and analyze this type of information in order to increase our Services’ functionality. These third party service providers have their own privacy policies addressing how they use this information. We encourage you to read and review these third parties’ privacy policies
PART B – USE OF YOUR INFORMATION
To accomplish any of the purposes listed below, we may combine Personal Information and Automatic Information, and non-personal information collected through your use of our Services. This information may be used in a variety of ways which are in keeping with the intent behind the collection of information. Some examples of said use may include:
(a) to connect you to members of our team;
(b) to enforce our Terms;
(c) to provide Mortgage planning advice;
(d) to complete and track your Mortgage application;
(e) to prevent, detect and investigate potentially prohibited or illegal activities, fraud and security breaches;
(f) to collect data on our Services;
(g) to improve our Services;
(i) to personalize your experience while using our Services; and
(j) to provide you with any additional information you may request.
For the purposes of administering your Mortgage application, we will share your personal information with the appropriate third party Lending Institution and/or Mortgage Broker. To provide a bit more context on how information is processed by Blink Mortgage, please refer to the diagram below:
Except as set forth above, your Personal Information will not be provided to any other Users of our Services.
1. Automatic Information
We also reserve the right to use Personal Information and Automatic Information as set forth in our Terms, if applicable.
2. Behavioural Remarketing
(a) Google Inc. (“Google”). Google AdWords is a remarketing service provided by Google. You may opt-out of Google Analytics for Display Advertising and customize Google’s Display Network ads by visiting Google’s Ads Setting page. Google also recommends installing the Google Analytics Opt-Out Browser Add-On. This service provided by Google allows visitors to prevent their data from being collected and used by Google Analytics.
(b) Facebook, Inc. (“Facebook”). We may use Facebook’s advertising services from time to time. You can opt-out of interest-based advertising from Facebook by visiting their website.
PART C – DISCLOSURE OF YOUR INFORMATION
1. To Help with Business Operations
We may disclose your information to our representatives, affiliates, suppliers or other third parties with which we do business (our “Business Partners”) when it is deemed necessary for our business operations.
From time to time, we may engage companies or individuals for certain services on our behalf including, without limitation, conducting audits, performing legal services, processing credit card payments, collecting feedback, and providing customer service. Our Business Partners and any other third-party service providers will only have incidental access to Personal Information to the extent required to perform their services. They are prohibited from the use of your Personal Information for any purpose other than assisting with our business operations.
2. Safety and Security
We may disclose your Personal Information as necessary to protect the safety or security of Users of our Services, to detect and prevent fraud or abusive behaviour, or when otherwise required or permitted by law.
3. Transfer or Sale
4. Legal Requirement
We may disclose your Personal Information, if required, to:
(a) tax authorities, supervisory authorities, police and other regulatory authorities as required by Law or in response to a subpoena, court order, or other legally valid inquiry or order;
(b) owners of intellectual property rights or such party’s representatives who may be considered, in good faith by such owner, to have had their owner’s rights violated by user of our Website and services, provided however, that the owner will be required to enter into an agreement to limit the use of the personal information provided only for purposes of the possible violation of an intellectual property right; and
(c) either prevent or minimize a criminal offense or to protect a person’s rights and personal and or financial health.
For the purposes of administering and tracking your Mortgage Application, we will share your personal information with the appropriate third party Lending Institution. Please note that if the Lending Institution requires additional consents, you will provide those consents directly to the Lending Institution.
PART D – PROTECTING, RETAINING AND STORING YOUR PERSONAL INFORMATION
Protection: In order to help prevent unauthorized access to, maintain data accuracy and ensure the correct use of your information, we have put in place commercially reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect through our Website. That said, we cannot guarantee that information provided to us through our Website will remain private, or that the information you transmit to us over the Internet will not be intercepted.
- Identification: To help prevent unauthorized access to your Personal Information you are responsible for keeping the username and password (collectively, “ID”) that you receive upon registration with our Services private and confidential. You are solely responsible for preventing the unauthorized use of your ID. If you suspect that your information has been compromised or that your account has been accessed without your consent, please contact us immediately at email@example.com or 866-243-3102.
- Retention: We store your Personal Information for up to seven (7) years from the date of collecting such Personal Information (as required under applicable law), or until your service access is terminated, whichever period may be longer. We will use commercially reasonable efforts to delete your Personal Information and any other information you may have provided to us in a reasonable time frame.
PART E – ELECTRONIC COMMUNICATIONS
Should you submit an inquiry through our Website, or otherwise communicate with us electronically, you consent to us responding to such inquiries electronically. We cannot guarantee that information that we send to or receive from you over the Internet will not be intercepted.
PART F – ACCESSING AND MODIFYING YOUR PERSONAL AND ACCOUNT INFORMATION
We want to ensure your Personal Information is accurate and up to date. If you notice any inaccuracies, please let us know. You can also access and modify your personal and account information using the tools provided in our Website. We will not modify your personal or account information.
At any time, you may request access to your Personal Information by contacting firstname.lastname@example.org or 866-243-3102. We will respond to your request within a reasonable time period, and process it as appropriate under applicable law. Your request may be subject to a processing fee as allowed under law.
PART H – HOW TO CONTACT US
ATTN: PRIVACY OFFICER