PRIVACY POLICY

Understanding Mortgage Capital Investment’s Privacy Policy

Introduction to Privacy Protection

At Mortgage Capital Investment (MCI), safeguarding the personal information of our customers, prospective customers, brokers, franchisees, and other stakeholders is paramount. This Privacy Policy outlines how we collect, use, and protect your personal information to ensure transparency and compliance with privacy laws.

Our Commitment to Privacy

MCI recognizes the importance of protecting your personal information and strives to give you as much control as possible over how your information is handled.

MCI and Its Franchisor Operations

As a franchisees, MCI does directly provide mortgage broker services. These services are exclusively offered by our franchisees CENTUM Total Mortgage Services Inc, who independently own and operated in Ontario under the registered trade name  Mortgage Capital Investment(MCI). While MCI implements stringent measures to ensure the privacy and security of personal information collected, we directly control the operations of our franchisees.

Privacy Policy Scope

This Privacy Policy applies to personal information collected by MCI during real estate transactions or other interactions. It addresses the type of personal information we collect, how we use it, and your rights regarding access and correction of your information.

Definition of Personal Information

Personal information refers to any information that identifies an individual, including:

• Contact information (e.g., name, business address, email, phone numbers)
• Publicly available information
• Aggregated information not identifying a specific individual
• Information about organizations

Types of Personal Information Collected by MCI

MCI collects personal information through various channels, including:

• Information voluntarily provided during interactions with MCI as franchisees (e.g., in-person, telephone, email)
• Information submitted through our website, such as contact forms and usage data (details available in our Website Privacy Policy)

Collection with Consent

Except where permitted by law, MCI collects, uses, and discloses personal information with the knowledge and consent of the individual. We ensure fair and transparent practices in handling personal information.

Use of Personal Information

MCI uses personal information for the following purposes:

• Connecting individuals with mortgage lenders or salespersons from our franchise network
• Assisting brokers in finding suitable mortgage solutions
• Utilizing personal information collected through our website as per our Website Privacy Policy

Disclosure of Personal Information

MCI may disclose personal information to third parties engaged to assist in providing services or products, strictly for the purposes described above. These service providers are bound by confidentiality agreements and privacy principles.

Consent and Your Rights

MCI collects personal information with your consent, which may be express or implied depending on the circumstances. We respect your right to withdraw consent, subject to legal or contractual restrictions.

Access to Your Personal Information

You have the right to access and correct your personal information held by MCI. Requests must be made in writing to our Privacy Officer, who will respond promptly and transparently in accordance with applicable privacy legislation.

Protection of Personal Information

MCI employs security measures to protect personal information against unauthorized access, use, or disclosure. These measures apply to both electronic and hard copy formats and are tailored to the sensitivity of the information.

Retention of Personal Information

We retain personal information only as long as necessary to fulfill its intended purpose and comply with legal requirements.

Changes to This Privacy Policy

MCI reserves the right to update this Privacy Policy periodically without notice. The current version will be posted on our website and deemed effective upon publication.

Accountability and Contact Information

MCI is accountable for the personal information under its control and has designated a Privacy Officer to oversee compliance with this policy and privacy laws. For inquiries or concerns regarding our Privacy Policy, please contact:

• Privacy Officer, Mortgage Capital Investment
• Contact Us

DISPUTE RESOLUTION

If You are unhappy about the collection, use or disclosure of your personal information by
MCI, we ask that You discuss the matter further with our Privacy Officer.

If You are not satisfied with the response, You may make an application or complaint to the appropriate Privacy Commissioner.

NOTE TO BROKERS AND SALESPEOPLE

In order to promote the services of our Franchisor and our brokerage and salespeople, MCI collects certain personal information about them, such as photographs and contact information, in a variety of ways, including through Online Office registration. This information is disclosed by MCI when it makes the information available for Customers to access on the Website or through other means by which MCI promotes their services.

Much of this information is business contact information, which is not subject to privacy law or this Privacy Policy. However, to the extent that such information is personal in nature, MCI will collect, use and disclosure this information in accordance with this Privacy Policy (see above) and, where applicable, with our Website Privacy Policy.

MCI FINANCIAL GROUP INC. WEBSITE PRIVACY POLICY

The following addresses the personal information Mortgage Capital Investment (“MCI”)
may collect about You during any interaction with our website (the “Website”).

YOUR ACCEPTANCE OF THIS WEBSITE PRIVACY POLICY

By using the Website, You signify your agreement with and acceptance of MCI’s Website Privacy Policy. If You do not accept this Website Privacy Policy, You must not access or use the Website.

MCI may, at any time, without notice or liability, revise this Website Privacy Policy by updating this posting. You should periodically revisit this posting to review any revisions to this Website Privacy Policy. If any revision is not acceptable to You, You must cease accessing and using the Website. If You continue to access or use the Website after any revisions are posted You will be deemed to have accepted those revisions.

TYPES OF PERSONAL INFORMATION

We receive two types of personal information from Customers who visit the Website: (1) personal information that Customers provide through registration or other communication on the Website; and (2) personal information MCI gathers through aggregated tracking procedures, such as tallying the number of page views throughout the Website over a given period of time. The second type of personal information enables us to tailor the Website content to better meet the needs of our customers. However, we assure You that MCI will not disclose your personal information to third parties except as is permitted by applicable law.

MCI AND ITS FRANCHISOR

As a franchisor, CENTUM https://www.centum.ca/ not provide mortgage broker services. Mortgage broker services are provided exclusively by CENTUM franchisees (“Franchisees”) such as MCI. Each Franchisee is an independently owned and operated mortgage broker business. Customers applying for mortgage services through the Website apply through a Franchisee, not through CENTUM. While MCI has undertaken extensive measures to control and ensure the privacy and security of personal information obtained through the Website, it does not own or controls the operations of its Franchisor. Customers who have concerns about the treatment of their personal information by a Franchisor with which they are dealing are urged to contact that Franchisee directly.

HOW DOES MCI COLLECT PERSONAL INFORMATION?
a. Registration: MCI does not collect your personal information through the Website except when such personal information is provided to us on a voluntary basis. For example, MCI will collect a user’s name, address, phone number and/or e-mail address and any additional details that a user chooses to provide if he or she completes the portion of the Website that requests that MCI or the Franchisor contact the user. If You choose not to provide your personal information please note that certain services associated with the Website may not be available to You as they cannot be supplied without your personal information. The personal information gathered through the Website is governed by the foregoing Privacy Policy.
b. Usage tracking:

i. Use of IP Addresses: An IP address is a number that is automatically assigned to your computer whenever You are surfing the Internet. Web servers automatically identify your computer by its IP address.

MCI and/or its affiliates collect IP addresses for the purposes of system administration, to report aggregated information to our advertisers, and to audit the use of the Website. When Customers request pages from the Website, our servers log the requesting Customers’ IP addresses. Except where You participate in any online transaction MCI may offer from time to time, we normally will not link IP addresses to anything personally identifiable, which means that Customers’ sessions will be logged, but Customer identity remains anonymous to us. We can and will use IP addresses to identify a Customer when we feel it is necessary to enforce compliance with our rules or terms of service or to protect our service, the Website, or any person, or where it is otherwise permitted by law.

ii. Use Of Cookies: Cookies are bits of information that a website transfers to an individual’s hard drive for record-keeping purposes. Cookies make Web-surfing easier for You by saving your preferences while You visit the Website. We never save passwords or credit card information in cookies. The use of cookies is an industry-standard, and, as such, You’ll encounter them at most major websites.

By showing how and when Customers use the Website, cookies help us see which areas are popular and which are not. Many improvements and updates to the Website are based on data collected using cookies, such as the total number of visitors and pages viewed in a given period of time. This kind of information is most easily tracked using cookies.

MCI and/or its affiliates have two primary uses for its cookies. First, we use them to specify preferences. For example, Customers can specify keywords across several categories or markets so You do not have to tell us over and over again about the kinds of homes You are interested in obtaining information about. Secondly, we use cookies to track Customer trends and patterns. This helps us to better understand our Customers’ needs and to improve areas of MCI and/or its Franchisees’ services that our Customers may find valuable. Sometimes, information from cookies is attached to messages sent to our Customer Service department. While all of these situations depend on the use of a cookie, You always have the option of disabling the receipt of cookies on your computer by adjusting the cookies setting in your Web browser preferences.

Most browsers are initially set up to accept cookies. You can reset your Web browser to either refuse all cookies or indicate when a cookie is being sent, with a concurrent option to accept or receive the cookie. However, note that some of the services offered on the Website will not function properly or may be considerably slower if You refuse to receive cookies. For example, without cookies, You will not be able to set personalized preferences. You might also encounter difficulties participating in online transactions offered on the Website from time to time.

Occasionally, You may receive cookies from our advertisers. MCI and/or its affiliates do not control these cookies. The use of advertising cookies sent by third-party servers is standard in the Internet industry.

iii. Other: We automatically collect anonymous statistical information regarding the usage of the Website. For instance, our Website will recognize the type of browser You are using (Netscape or Internet Explorer), the address of the Internet Service Provider you are using, the site that linked You to the Website, the pages You visit at the Website and similar information. None of this information identifies You personally.

WITH WHOM DOES MCI SHARE YOUR PERSONAL INFORMATION?

As a general rule, MCI will not disclose any of your personal information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under other specified circumstances, including those described below:

a. Business Partners & Sponsors: MCI may disclose some or all your personal information to business partners or sponsors, but this use will be specifically described to You prior to either the collection or transfer of the personal information. Many promotions offer opportunities to request additional information from sponsors. By requesting more information, You give MCI permission to transfer your personal information to the sponsor so they can fulfill your request. In many instances, only your e-mail address will be shared with the sponsor. If we intend on sharing more personal information with the sponsor than your e-mail, You will be notified prior to the transfer.
b. Third-Party Data and Data in the Aggregate: From time to time, on the Website, You may be offered the opportunity to receive material or special offers from third parties. If You opt to receive information from these third parties, MCI will (with your permission) share your name and e-mail address with such third parties. Under confidentiality agreements, MCI may match Customer information with third-party data. Also, MCI may disclose aggregated Customer statistics (i.e., where we disclose a characteristic of our Customers as a group and not as individuals) in order to describe our services to prospective partners, advertisers, and other third parties, and for other lawful purposes.
c. Service Providers: Information MCI receives through the Website is provided to service providers retained by MCI including Filogix Inc. , Axiom Innovations Inc. and WhereToLive.com, Inc., in order to organize and distribute appropriate personal information to enable MCI and its Franchisees to communicate with its customers and to provide information about marketing initiatives that may be of interest to its customers.
d. Other: MCI may disclose account information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating MCI’s Terms of Use or may be causing (either intentionally or unintentionally) injury to or interference with MCI’s rights or property, other MCI Customers, or anyone else that could be harmed by such activities. MCI may disclose or access account information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service, and improve our products and services. Note that to the extent that MCI retains a Canadian and U.S. located service provider (including, for example, Axiom Innovations Inc. and WhereToLive.com Inc.) the personal information in that service provider’s control or possession is subject to the laws of the jurisdiction in which it operates.

HOW CAN YOU CONTROL THE USE OF YOUR PERSONAL INFORMATION?

In case You change your mind or some personal information changes (such as your postal code or e-mail address), we will endeavour to provide a way to correct, update or remove the personal information You give us. Additionally, to keep You in control of the communications directed to You, we offer Customers the opportunity to “opt-out” of having personal information shared with parties outside of MCI and/or its affiliated companies. If You wish, for any reason, to update your personal information or if You object to any use of your personal information described in this Website Privacy Policy, You may contact MCI’s Privacy Officer:

WHAT HAPPENS WHEN YOU LINK TO A THIRD PARTY WEBSITE?

You should be aware that when You are on the Website You could be directed to other third-party websites that are beyond our control. There may, from time to time, link to other third party websites from the Website that takes You outside our service areas. For example, if You “click” on a banner advertisement on the Website, the “click” typically takes You off the Website. These other sites may include websites of advertisers, sponsors and partners that may use MCI’s and/or its affiliates’ and/or its Franchisors’ logos as part of a co-branding agreement. These other websites may send their own cookies to Customers, or otherwise, collect data or solicit information.

MCI and its affiliates and Franchisors do not control such third party websites, and, therefore, are not responsible for their content. The provision of hyperlinks to these websites does not imply any endorsement of the material on such websites or any association with their operators. This Website Privacy Policy does not extend to anything that is inherent in the operation of the Internet and which is beyond the control of MCI, its affiliates or its Franchisors.

Please keep in mind that whenever You give out personal information online (for example, via message boards or chat lines), that personal information can be collected and used by people You do not know. While MCI and its affiliates strive to protect their Customers’ personal information and privacy, we cannot guarantee the security of any personal information You disclose online and so You disclose such information at your own risk.

IS YOUR PERSONAL INFORMATION SECURE FROM OTHERS USING THE MCI WEBSITE?

The importance of securing your personal information is of the utmost concern to us. We exercise great care in providing secure transmission of your information from your computer to our servers. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, MCI and its affiliates cannot promise or warrant the security of any personal information You transmit to us, including through the use of our online products or services. Any such transmission is done so at your own risk. Once we receive your transmission, MCI uses industry-standard efforts to safeguard the confidentiality of your personal information, such as firewalls and Secure Socket Layers. However, ironclad security does not yet exist on the Internet.