Privacy Policy
Last Updated: August 2024
BrightPath Financial Corporation (“BrightPath”) values and respects the privacy of its users.
This Privacy Policy outlines how we collect, use, disclose, and process personal information in connection with our website, available at https://brightpathfinancial.ca/ (the “Website”), and through our other interactions with you.
BrightPath has appointed a Privacy Officer responsible for overseeing our compliance with this Privacy Policy. Please refer to the “Contact Us” section for information on how to contact our Privacy Officer.
CONTENTS OF THIS PRIVACY POLICY
- Collection and Use of Personal Information
- How Personal Information is Collected
- Disclosure of Personal Information
- Cookies and Information About Our Website
- Interest-Based Advertising
- Safeguards and Retention
- Your Choices
- Access to Personal Information
- Changes to this Privacy Policy
- Contact Us
COLLECTION AND USE OF PERSONAL INFORMATION
Request a Rate Quote:
When you request a mortgage rate quote, you will be asked to provide information such as your first and last name, email address, phone number, property value, mortgage amount, transaction type (purchase, refinance, or transfer), and mortgage needs, including type of loan, when you plan on purchasing a home, whether you are a first-time home buyer, estimated down payment, and credit score range (if known). We use this information to contact you regarding your mortgage needs and to obtain personalized mortgage quotes from third-party lenders. We will also obtain your consent for a credit check as described below.
Credit Reports:
We will request your consent to obtain your credit report (including credit score) from a credit reporting agency and share this information with third-party lenders so that they may provide us with personalized mortgage quotes and assess your eligibility for a mortgage. Your credit report may include information such as the types and amounts of credit advanced to you, payment histories, negative banking items, collection actions, legal proceedings, previous bankruptcies, and other information reported by your creditors. You authorize credit reporting agencies to provide such information to us.
Social Insurance Number:
If we are unable to obtain your credit report based on your name, date of birth, and mailing address alone, we may request you to provide additional information, such as your social insurance number, on an optional basis, to help us identify you with a credit reporting agency.
Mortgage Application:
If you request our assistance in completing your mortgage application with a particular lender, we collect additional information required to complete your application, such as your date of birth, income, employment information, credit report, and information about your assets and liabilities. We use this information to complete your mortgage application on your behalf and send your completed application to the lender.
Appraisers:
If required by a lender as part of the mortgage application, we may collect an appraisal report prepared by a third-party appraiser.
Account Creation:
To access certain services on our Website, such as using our mortgage solution, you will be required to create an online account and provide personal information such as your first and last name, email address, and a password that you create. We use this information to create and administer your online account. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls, or email messages).
Marketing Communications:
We may obtain your consent to use your information to send you communications by mail, email, or telephone, marketing or promoting products and services that may be of interest to you. You can opt-out of receiving marketing offers at any time by clicking on the unsubscribe link included in our marketing email communications or by contacting us as set out under the “Contact Us” section below. Please note that if you unsubscribe, you may continue to receive certain transactional or account-related communications from us.
Call Recording:
We may monitor and record our telephone conversations with you for training and quality assurance purposes. You will be provided with notice at the beginning of any call that is being recorded. If you do not wish to have your call recorded, please let us know.
Customer Service:
When you contact us with a comment, question, or complaint, you may be asked for information that identifies you (such as your name, address, and phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service and product and service offerings.
Employment:
In connection with a job application or related inquiry, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). This information will be used for assessing your suitability for employment and responding to your application for current and future career opportunities.
Survey and Customer Research:
From time to time, we may offer you the opportunity to participate in one of our surveys or other customer research. The information obtained through our surveys and customer research is used in an aggregated, non-personally identifiable form to help us understand our customers and enhance our product and service offerings.
Contests and Promotions:
When you enter a contest or participate in a promotion, we may collect your name, address, phone number, email address, and other information you provide. This information is used to administer your participation in the contest, sweepstakes, or promotion.
HOW PERSONAL INFORMATION IS COLLECTED
We collect personal information directly from you and from third parties such as appraisers, credit reporting agencies, and our Referral Partners.
DISCLOSURE OF PERSONAL INFORMATION
We will not disclose, trade, rent, sell, or otherwise transfer your personal information without your consent, except as otherwise set out herein.
Referral Partners:
Your personal information may be transferred (or otherwise made available) to our business partners who refer business to us and/or provide services that might interest you after we make an outbound referral. These Referral Partners provide services, including but not limited to, sending or referring potential business to us or providing their services to you directly. Your personal information may be shared with these Referral Partners upon receiving your initial inquiry or upon closing your mortgage with us. Your personal information is shared with these Referral Partners for the purpose of those entities providing you with their products and/or services. We also share your personal information with these Referral Partners for analytics, troubleshooting, and their internal business functions. We may receive compensation from or provide compensation to our Referral Partners concerning your mortgage transaction.
Service Providers:
Your personal information may be transferred (or otherwise made available) to our affiliates and other third parties who provide services on our behalf. We use service providers to send communications, provide back-office support functions, host the Website, operate certain of its features such as forms for requesting rate quotes, or manage and analyze data and our advertising effectiveness. Your personal information may be maintained and processed by BrightPath and its affiliates and third-party service providers in Canada, the US, or other jurisdictions. In the event personal information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement, and governmental authorities in accordance with those laws. Our service providers are given the information they need to perform their designated functions and are not authorized to use or disclose personal information for their marketing or other purposes.
Prospective Partners:
We may share aggregated, non-personally identifiable statistics about users of our services with prospective partners for market research.
Mortgage Lenders or Insurers:
If you apply for a mortgage, we will share certain personal information we have about you (including information contained in your mortgage application and credit report) as well as your responses to our mortgage questions with third-party lenders so that they can provide a personalized mortgage rate and assess your eligibility for a mortgage. We may also share your information with mortgage insurers so that they can provide you with insurance rates and options. Your personal information will be treated in accordance with the lender’s or insurer’s privacy policy, which we recommend you review carefully.
Consumer Reporting Agencies:
BrightPath will obtain your consent to provide your first and last name, date of birth, mailing address, and telephone number to Equifax (or another consumer reporting agency) for the purposes set out above in this Privacy Policy.
Appraisers:
BrightPath relies on the valuation expertise of third-party appraisers to determine the value of your target property. BrightPath may share information about your target property, such as the property address, with a third-party appraiser to obtain an appraisal report included as part of your mortgage application.
Legal/Compliance:
BrightPath and its other service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by governmental authorities, courts, or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing, or preventing fraud, or as otherwise required or permitted by applicable laws. Your personal information may also be disclosed where necessary for the establishment, exercise, or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of Business:
Personal information may be transferred as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of BrightPath or as part of a corporate reorganization or stock sale or other change in corporate control.
COOKIES AND INFORMATION ABOUT OUR WEBSITE
Visiting our Website:
In general, you can visit the Website without telling us who you are or submitting any personal information. However, we and/or our service providers (such as Google Analytics) collect IP addresses (the Internet address of a computer) to track the Website visitor’s session while the visitor remains anonymous. We analyze this data for certain trends and statistics, such as which parts of the Website users are visiting and how long they spend there. We do not link your IP address to anything that could identify you unless we notify you otherwise.
Cookies and Tracers:
Our Website uses a technology called “cookies.” A cookie is a tiny element of data that our Website sends 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 its features. We may also use a technology called “tracer tags” or “Web Beacons” on our Website and in our emails. This technology allows us to understand which pages you visit on our Website or what email content you find interesting.
INTEREST-BASED ADVERTISING
We work with third-party advertisers that use cookies and similar technologies to collect information about your online activity across different websites and services, including your searches, the pages you visit, and the date and time of your visit. This information may be used to display advertisements for BrightPath on other websites or services.
You can learn more about interest-based advertising and opt-out of some of these practices by visiting https://youradchoices.ca/en/tools or https://www.networkadvertising.org/. Please note that even if you opt-out, you may continue to receive advertisements, but they will not be tailored to your interests.
SAFEGUARDS AND RETENTION
Security:
We take your privacy seriously and have implemented physical, organizational, and technological safeguards to protect personal information against loss or theft, unauthorized access, disclosure, copying, use, or modification. The only employees, agents, and contractors who have access to personal information are those who require it to fulfill their job responsibilities.
Retention:
We have personal information retention processes designed to retain personal information of our clients for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.
YOUR CHOICES
You can opt out of receiving marketing communications by clicking the “unsubscribe” link at the bottom of any marketing email or by contacting us as set out under the “Contact Us” section below.
ACCESS TO PERSONAL INFORMATION
You have the right to request access to the personal information we hold about you and request corrections to your personal information to ensure it is accurate and up-to-date.
CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our personal information practices. We will notify you of significant changes by posting the updated policy on our Website or by sending you an email notification. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.
CONTACT US
If you have any questions or concerns about our Privacy Policy or our personal information practices, or if you wish to access, update, or correct your personal information, please contact us by email at [privacy@brightpathfinancial.ca] or by mail at:
BrightPath Financial Corporation
500-7030 Woodbine Avenue
Markham Ontario L3R6G2
Attention: Privacy Officer