Our Commitment to Privacy

Haventree Bank is committed to maintaining the accuracy, confidentiality and security of your personal information. We value the trust you have placed in us and wish to provide assurance that nothing is more important to us than the security and appropriate use of your personal information.

This privacy statement is designed to inform you of the policies and practices we have put in place to
manage your personal information. We encourage you to read this privacy statement so that you can better understand how we collect, use, share and protect your personal information.

Accountability

We have appointed a Privacy Officer to oversee compliance with our privacy obligations and commitments. If you elect to contact our Privacy Officer, you may use one of the following methods;

Haventree Bank – Privacy Department
Phone 416 348 7922
Email privacyofficer@haventreebank.com
Mailing Address Haventree Bank
Privacy Department
P.O. Box 1160, Station TD
Toronto, Ontario
M5K 1P2

What is Personal Information?

Personal information is any factual or subjective information, recorded or not, about an identifiable individual such as, but not limited to, your name, address, age, date of birth, marital status, income, social insurance number, other information of a personal nature such as ethnicity, religion or political affiliations, and any information about our relationship with you including account numbers and the status of your accounts.

What We Collect and How We Collect It

We collect personal information about you in order to:

  • Confirm your identity;
  • Determine your eligibility for our products and services;
  • Set up your accounts and provide ongoing service;
  • Meet legal and regulatory requirements;
  • Fulfil the “use” and “disclosure” purposes identified below; and
  • Protect you from error and fraud.

The information we collect includes but is not limited to:

  • Name and address;
  • Identification documents;
  • Credit and financial information such as your employment history, income sources, assets, liabilities, credit history, bank accounts, payment preferences and social insurance number;
  • Publicly available social media postings that you may make; and
  • Any additional information required in respect of a specific product or service that you have applied for.

This information may be obtained, with your consent:

  • Directly from you by phone, in writing, application forms or email;
  • Directly from your spouse, family member or other person who possesses personal information about you;
  • From a broker or other intermediary acting on your behalf;
  • From third parties such as credit agencies, your employer or others outside our organization; or
  • May be generated directly by us in the process of setting up and servicing your account(s).

Consent

Haventree Bank will, in most instances, obtain your express consent to collect, use or disclose personal information. The method by which the consent will be obtained will be applicable to the type of personal information being collected, used or disclosed. Haventree Bank will obtain your express consent (verbal, written or electronic) to collect, use or disclose sensitive personal information such as personal financial information.

Haventree Bank will rely on implied consent to collect, use or disclose your personal information in situations where you may reasonably expect us to require your personal information in order to provide services to you;

We obtain your consent at the time that we collect your personal information. In certain circumstances,
your consent may be obtained after collection but prior to our use or disclosure. If we plan to use or disclose your personal information for a purpose not previously identified (either in this privacy statement or separately), we will advise you of that purpose before such use or disclosure.

Where we have obtained your personal information from third parties who have collected it in the course of performing a service for us or otherwise, we will take reasonable steps to ensure that such third parties have your consent to disclose your personal information to us and for us to use the information for purposes as we require and for which you have consented.

We may collect information about you without your knowledge or consent where permitted or required to by applicable law or regulatory requirements. You may change or withdraw your consent at any time,

subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer in writing using the contact information above. In certain circumstances, the withdrawal of consent may render us unable to continue to provide products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service

Use and Disclosure of your Personal Information

Use

In addition to the purposes listed under “What We Collect and How We Collect It”, we use your personal information to:

  • record, evaluate and respond to applications for mortgage financing or other financial products;
  • administer, monitor and assess your mortgage or other financial products with us on an ongoing basis and to otherwise service your account with us;
  • manage our credit and business risks and operations;
  • maintain records relating to your mortgage/financial product applications with us and subsequent mortgage/financial products that you may have with us;
  • send information to you about products or services we believe may be of interest to you; and
  • comply with legal or regulatory requirements.

Disclosure

We may share your personal information with our affiliates, contractors, consultants, suppliers, agents, service providers, business or marketing partners, and other third parties who require such information to assist us with managing our relationship with you and providing services to you. Some of these recipients may be located in jurisdictions outside of Canada where the laws of the jurisdiction may provide for a different level of protection for personal information than is provided under Canadian laws and while the information is situated in such other jurisdictions it may be accessed by the courts, law enforcement and national security authorities. If you would like further information about our use of any of these third parties located outside of Canada, please contact our Privacy Officer at the address listed above.

We may also disclose your personal information to:

  • Credit bureaus, credit reporting agencies, collection agencies, past and present employers, past and present creditors, financial institutions, landlords, spouses and others to confirm your financial and employment status and your initial and ongoing eligibility for credit;
  • Persons retained to administer or service your account for the purpose of such administration or servicing;
  • Other persons as necessary for the provision of credit services to you and the protection of any security interest in any loans we may have with you;
  • Auditors, regulators and their agents as permitted or required by applicable law or regulatory requirements;
  • Comply with valid legal processes such as power of sale processes, search warrants, subpoenas or court orders;
  • Administer or service your account or other credit product;
  • Protect the rights and property of Haventree Bank;
  • Investors as necessary for them to conduct due diligence on Haventree Bank;
  • Mortgage insurers and other insurers;
  • Organizations and government institutions who need the information in emergency situations and the disclosure is necessary to protect the safety of a person or group;
  • Third parties where the personal information is publicly available, and the disclosure and subsequent use is permitted under applicable law;
  • Tenants as necessary in a power of sale proceeding or other legal process to advise them of the proceedings and to attempt to locate you, if necessary; and
  • To any other persons and for any additional purposes for which we have obtained your consent.

By providing your personal information to us and/or executing a mortgage application form, you consent to our disclosure of this information to our service providers and other third parties as described in this privacy statement, including those that maybe located outside of Canada, for processing your requests, providing services to us or to you and to otherwise operate our business. For clarity, and without limiting the foregoing, you acknowledge and agree that the third parties to whom we disclose your personal information is permitted by you to receive such personal information;
maintain records relating to the personal information; hold, use, communicate and disclose the personal
information received from Haventree Bank and otherwise collected from third parties and sources such as credit reporting and collection agencies, financial institutions, past or present employers, past or present creditors, landlords and tenants, family members or any other person for the purposes described in this privacy statement.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

Marketing Messages

we or our suppliers agents service providers business marketing partners may send you information about product and services that believe be of benefit to you where applicable rely on existing relationship with these messages electronically if do not have and you will obtain your opt-in consent opt out receiving at any time.

Access to your Personal Information

Haventree Bank strives to keep your personal information accurate, up to date and relevant for its intended use. You can assist us by updating your personal information with us (e.g. change of address) as changes occur.
You can ask to see your personal information. If you want to review, verify or correct your personal
information, please contact our Customer Service department, and if our Customer Service department is unable to help you, please contact our Privacy Officer in writing using the contact information above. When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. We will respond to your request within 30 days.

Your right to access the personal information that we hold about you is not absolute. There are
instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
If we cannot provide you with the requested access to your personal information, we will inform you of
the reasons why, subject to any legal or regulatory restrictions.

Updating your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during our relationship, please inform our Customer Service department using one of the following methods;

Haventree Bank – Mortgage Servicing Department
Phone 1 855 272 0051 (toll-free) 647 277 0051 (local) 416 361 0152 (local)
Email mortgageservicing@haventreebank.com
Mailing Address Haventree Bank
Mortgage Servicing Department
P.O. Box 22248, Bankers Hall
Calgary, Alberta
T2P 4J6

If our Customer Service department is unable to help you, please contact our Privacy Officer using the contact information above.

In some circumstances, we may not agree with your request to change your personal information and
will instead append an alternative text to the record in question.

Security of Your Personal Information

Haventree Bank maintains physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Haventree Bank will take every necessary step to ensure the protection of your personal information, including:

  • Shredding of documents containing personal information;
  • Physical security measures – restricted access to facilities and locked filing cabinets;
  • Electronic security measures for computerized personal information – password protection and personal identification numbers;
  • Organizational processes and procedures including limiting access to your personal information to individuals on a need-to-know basis;
  • Destroying, erasing or masking your information in accordance with our records retention policy; and
  • Ensuring that third parties who are given access to your personal information protect and secure your personal information in similar manner.

Retention of Your Personal Information

Haventree Bank only retains your information for as long as necessary to fulfill the purpose for which it was originally collected or as required by law.

Respecting and Responding to Your Privacy Concerns/Complaints

Your privacy concerns matter to us. If you have any questions or concerns about your privacy rights or how we manage your personal information, please contact our Customer Service department using the contact information provided above.

We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you. If our Customer Service department is unable to help you, please contact our Privacy Officer using the contact information provided earlier. Please refer to our Privacy Complaint Procedures under “Contact Us” or follow this link: www.haventreebank.com/privacy-statement/.

If, after following these procedures, you remain dissatisfied with our response, you are entitled to make
a written submission to the Privacy Commissioner of Canada using the following methods;

Office of the Privacy Commissioner of Canada (OPCC)
Phone 1 800 282 1376 (toll-free) Fax: 1 819 994 5424 TTY: 1 819 994 6591
Website www.priv.gc.ca
Mailing Address Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3

Information about our Website

Haventree Bank gathers information about visitors who are not personally identified. This information includes the type of internet browser and operating system you are using, IP (Internet Protocol) addresses and other related information such as page requests and average time spent on our website. Please note the information will only be gathered while the visitor is on the site. No information is gathered about other third-party sites the visitor has accessed. The information collected is analyzed to help us understand trends and patterns, and to improve the content, design and user experience of the website.

In certain sections of the site, Haventree Bank may invite you to contact us, request information or complete a registration form. In these cases, we request contact and other related information. If you choose to provide this information, we will use it only to contact you as requested, or to register you to access certain sections of our website or for specified events

Cookies: Our website uses a technology called “cookies”. A cookie is a tiny element of data that our website can send to your browser, which may then be stored on your hard drive so we can recognize
you when you return. You may set your web browser to notify you when you receive a cookie. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all the features of our website.

Tracer Tags & Web Beacons: Some areas of the website may also use “web beacon” technologies. Web beacons work in conjunction with cookies and let us know what portions of our site are of interest to our visitors and to help us provide you with tailored information from our website. If you turn off cookies, web beacon technologies will still detect anonymous visits, but the notices they generate cannot be associated with other information that is collected and are disregarded.

Third-party links: Our website may contain links to other sites that Haventree Bank does not own or operate. Also, links to our website may be featured on third-party websites on which we advertise. Except as described in this privacy statement, we will not provide any of your personal information to these third parties without your consent. 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 have separate and independent privacy statements, notices and terms of use, which we
recommend you read carefully. We do not have any control over such websites and therefore we have no responsibility.

Customer Testimonials/Case Studies/Reviews: We post customer testimonials/comments/reviews on our website, which may contain information about the customer. We obtain each customer’s consent via email prior to posting the customer name and testimonial.

Legal Disclaimers

From time to time, Haventree Bank may make changes to our Privacy Policy to reflect changes in our legal or regulatory obligations, or in the way we deal with your personal information. Any changes that affect your rights will be communicated to you via this statement and posted on our website. We encourage you to refer to it on a regular basis.

This privacy statement does not create or confer upon any individual any rights, or impose upon Haventree Bank any obligations outside of, or in addition to, any obligations imposed by Canada’s federal privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Disclosure and Canada’s federal privacy laws, this Statement shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

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