PRIVACY POLICY

HRU Financial, HRU Mortgage Investment Corporation, and all affiliates and subsidiaries (hereinafter referred as “HRU Group”) have developed their privacy policy as outlined below to comply with the federal Personal Information and Electronic Documents Act (“PIPEDA”) and adopting the ten principles from the Model Code for the Protection of Personal Information.

What is Personal Information?

Personal information is any information that is specific to you. We use it not only to identify you as our customer but also to understand your needs and how we can serve you better. This information includes, but is not limited to, your name, address, telephone number(s) or other identifying information, such as your date of birth, age, marital status, and identification numbers (e.g., Social Insurance Number). Some information gathered may be financial and would include such information as your place of employment, annual income, financial information, and credit records. It does not include business contact information that would typically appear on a business card, or that is available in public records such as public telephone directory information and professional and business directories open to the public.

Why Do We Collect Your Personal Information?

We collect information from you and about you, only with your consent, or as required or permitted by law. We will inform you of the purposes for which we need the personal information that we collect and only collect information that is pertinent for providing the service requested. The data will be collected directly from you or your authorized representative(s), in completed applications and forms, through other means of correspondence, such as the telephone, mail, or the Internet. In some cases, and with your consent, we may need to ask an independent source to verify or provide supplemental information. These sources could include service providers such as financial institutions, your employer, or credit reporting agencies.

There are a number of reasons why we collect and use your personal information. Most of these relate to the day-to-day operations of the HRU Group and facilitate the delivery of services and products that we provide to you. In general, we use the information to:

Confirm your identity and to understand your needs
Provide ongoing service for the products and services that we provide for you
Determine the suitability and your eligibility for our products and services for you
Inform you about products and services that may meet your needs
Comply with legal requirements and regulations, including tax reporting obligations under the Federal Income Tax Act.

We will only keep your personal information in our records for the length of time required to comply with legal or regulatory requirements.

The Ten Principles

Accountability: Maintaining the security and confidentiality of your personal information is a part of the responsibility of every employee at the HRU Group. Employees and our suppliers are informed about and must comply with the policies and procedures that we have established regarding the collection, use, and storage of the personal information collected. We have designated individuals who are responsible for monitoring our ongoing compliance with the Privacy Principles.
Identifying purposes: Your information is collected to identify you as our customer and to provide you with products and services. Your information helps us to determine your needs, what products and services would suit you, and your eligibility, as well as to provide you with information on other products and services (provided by us or by our affiliates) that you might be of interest. We also collect your information to comply with laws and regulations and to maintain both your interests and ours.
Consent: Your consent is required for the collection, use, and disclosure of personal information, subject to certain exceptions (legal or medical exceptions). Your consent may be given verbally, electronically, in a written format, or through authorized representatives.
Limiting collection: We collect your personal information directly from you (or your authorized representative) for the purposes previously mentioned. We may also collect information from external sources such as credit bureaus, employers, and other lenders. Limiting use, disclosure, and retention: Your personal information may only be used or disclosed for the purposes for which it was collected, other purposes you consent to, or as required or permitted by law. It may only be kept for as long as is necessary to satisfy the purposes for which it was collected, or as required or permitted by law.
Limiting use, disclosure, and retention: Your personal information may only be used or disclosed for the purposes for which it was collected, other purposes you consent to, or as required or permitted by law. It may only be kept for as long as is necessary to satisfy the purposes for which it was collected, or as required or permitted by law.
Accuracy: We will strive to maintain the accuracy and relevance of your personal information. It is your responsibility to notify us if there is any change to your information so that our files can be updated accordingly.
Safeguards: The security of your personal information involves physical, organizational, and electronic methods. We only contract with suppliers that have a proven track record of securely handling personal information and share our policies. We restrict physical access to areas where information is collected, stored, or processed to authorized employees. We also maintain electronic security measures such as password protection to prevent unauthorized access to our electronic records of personal information.
Openness: Information about our privacy policies and practices for managing your personal information shall be made available to you upon request. This information is provided in a comprehensible format. For inquiries regarding our policies and procedures, please contact our Privacy Officer at the address listed below.
Individual access: When you request it, 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. We will provide this information to you promptly. We will provide you with access, upon request, to your personal information, except in certain situations. We will explain the reason for this lack of access when you make your request. We will not provide certain information if it:
- Contains references to other persons
- Is subject to solicitor-client or litigation privilege
- Contains our own “proprietary information” (our scoring calculations, risk assessment formulas or recommendation processes)
- Cannot be disclosed for legal reasons
- Is used for the detection and prevention of criminal activity and dealings in proceeds of crime
We will not record in your file when personal information is disclosed to third parties for routine purposes, like:
- Reporting to Canada Revenue Agency (T5 or other reports)
- Regular updating of credit information to credit bureaus
- Information is provided to legal counsel for collection. If it is discovered that the information that we have on file is incorrect or obsolete, we will update our records accordingly. We reserve the right to decline a requested correction but will append a notation to the records of your requested alternative information.
  Whenever possible, we will correct any information which we may have given to an outside organization.
If it is discovered that the information that we have on file is incorrect or obsolete, we will update our records accordingly. We reserve the right to decline a requested correction but will append a notation to the records of your requested alternative information. Whenever possible, we will correct any information which we may have given to an outside organization.

If a third party (such as a credit bureau or reporting agency) has given us information that you believe is incorrect, we will provide you with the name and address of that party so that you can contact them to correct the information that they maintain.
Provide recourse: You may contact us if you have any inquiries or concerns regarding our privacy policies and practices. We will reply to your questions and concerns as quickly as possible. All inquiries should be sent to our Privacy Officer at the address listed below.

The security and confidentiality of your personal information is a high priority for the HRU Group. We hope that this Privacy Code is informative and useful to you. If you have any concerns regarding this Privacy Code or have any further questions, you may bring them to our attention as follows:

Compliance Officer
HRU Mortgage Investment Corporation