Privacy Policy
UnionLink Mortgage Limited (ULM) (“we”, “us”, or “our”) is committed to protecting the privacy and confidentiality of personal information we collect in the course of providing mortgage lending and related services.
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At UnionLink Mortgage Limited (ULM), our core business of providing mortgage solutions requires the careful handling of sensitive client data. We operate as a licensed mortgage lender in Ontario, Alberta and British Columbia, with our post-fund servicing outsourced to institutional lender.
This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Personal Information Protection Acts of Alberta and British Columbia.
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Collection of Personal Information
We collect various types of Personal Information (PI) necessary to underwrite, fund, and service your mortgage. This includes, but is not limited to, the following categories:
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Identification and Contact Information: Your full name, residential address, telephone number, email address, date of birth, and Social Insurance Number (SIN used for tax reporting and accurate credit file matching, where permitted by law).
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Financial and Credit Details: Your current employment status, income verification (pay stubs, T4s, Notices of Assessment), details regarding your assets (e.g., bank accounts, investments), liabilities (existing debts), and comprehensive credit reports and scores obtained from credit reporting agencies.
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Property and Mortgage Details: The address and type of property being financed, the requested mortgage principal and terms, and details of the intended use of the property.
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We only collect information that a reasonable person would consider appropriate in the circumstances.
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Purpose of Collection, Use, and Disclosure
The personal information we collect is used only for the purposes described below, or as otherwise permitted or required by law:
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Confirmation of Identity: To comply with legal and regulatory obligations, including the requirements set by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), ensuring that we are dealing with the correct individual and mitigating financial crime risk.
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Credit Assessment and Underwriting: To verify your financial capacity, employment stability, and creditworthiness in order to determine your eligibility for a mortgage product, assess the level of risk, and ensure the loan's suitability.
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Mortgage Processing and Funding: To prepare, execute, and fund the mortgage and/or loan commitment, which involves registering the mortgage charge on the property and coordinating the transfer of funds.
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Regulatory and Legal Compliance: To meet obligations under Canadian federal and provincial laws, including anti-money laundering and anti-terrorist financing requirements, and to comply with all applicable provincial licensing and consumer protection regulations in British Columbia, Alberta, and Ontario.
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Post-Fund Account Servicing: To establish and transition your mortgage account to our institutional lender which manages all ongoing loan administration, payments, statements, and tax reporting after closing.
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Risk Mitigation and Insurance: To provide necessary information to mortgage insurers to secure the mandatory insurance coverage required for your loan.
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We only collect and use the minimum amount of personal information necessary to achieve these purposes.
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Disclosure and Sharing of Personal Information
To successfully process, insure, register, and service your mortgage, we may share your personal information with a variety of external parties, including:
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Mortgage Insurers (e.g., CMHC, Sagen, Canada Guaranty) for mandatory insurance coverage
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Title and Closing Services (e.g., First Canadian Title) for property title searches, insurance, and closing coordination
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Credit Reporting Agencies to obtain credit reports for underwriting and to report ongoing payment history;
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Government and Regulatory Authorities (e.g., FINTRAC, CRA) to meet legal and compliance obligations in British Columbia, Alberta, and Ontario
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Professional Service Providers (e.g., appraisers, legal counsel, consultants) required to complete and administer your mortgage
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Co-Borrowers, Guarantors, or Estate Representatives connected to your loan.
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Institutional Lender and Servicing Provider for post-funding account servicing and administration.
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We require all third parties and service providers to maintain the confidentiality and security of your personal information, and to only use it for the purpose for which it was shared.
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Consent
We rely entirely on your mortgage broker to obtain your informed and express consent during your initial transaction with ULM for the collection, use, and disclosure of your personal information, except where permitted or required by law.
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By submitting a mortgage application through a licensed broker, you consent to ULM collecting your personal information for the purposes of assessing, processing, and funding your mortgage. You also consent to ULM disclosing your personal information to the institutional lender and servicing provider, who will be responsible for ongoing post-funding mortgage account servicing, including payments, statements, and related administration. In addition, your personal information may be disclosed to necessary third parties, such as default mortgage insurers, title and closing service providers, and credit reporting agencies, for the purposes described in this Privacy Policy.
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You may withdraw your consent at any time by providing reasonable notice, subject to legal or contractual restrictions. Please note that withdrawing consent may limit our ability to provide or continue to provide mortgage services.
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Security and Retention
We are committed to protecting your personal information using security safeguards appropriate to the sensitivity of the information, as required by applicable federal and provincial privacy legislation. We employ a combination of physical, organizational, and technological safeguards to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification. These safeguards include:
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Technological Controls: The use of security technologies such as encryption (where appropriate), secure data transmission methods, firewalls, intrusion detection systems, and role-based access controls to protect electronic records.
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Organizational Controls: Limiting access to personal information to only those employees, and authorized representatives of ULM, who require the information to perform their job functions, such as underwriting, compliance, or loan servicing).
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Physical Controls: Securing physical documents, (where they exist, in locked filing cabinets, secured premises, with appropriate monitoring and access controls.
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Third-Party Accountability: Requiring third-party service providers and partners who receive personal information to implement appropriate safeguards and to protect personal information through contractual and other legally required measures.
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with applicable legal, regulatory and business requirements. As a licensed mortgage lender/brokerage operating in Canada, we generally retain records relating to mortgage applications and agreements for a period consistent with regulatory requirements, which is typically at least six (6) years following mortgage discharge, expiry of the term, or the completion or cancellation of the transaction.
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Access and Correction
You have the right to know what personal information we hold about you and to ensure it is accurate and complete.
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Right to Access: Upon written request, and subject to applicable legal exceptions (such as solicitor-client privilege or personal information relating to another individual). ULM will provide you with access to your personal information, including information about how it has been used and to whom it has been disclosed. If access cannot be provided, we will explain the reasons for the refusal.
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Right to Correction: If you believe that any of the personal information we holds about you is inaccurate, incomplete, or outdated, you have may request a correction. Where appropriate, we will correct the information as soon as reasonably possible. If a correction is not made, we will record your request and retain it with the relevant information.
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Requests must be made in writing and may require identity verification. We will respond to access and correction requests within the timeframes required by applicable privacy legislation.
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Website Information and Cookies
When you visit our website, we may collect limited technical information such as IP address, browser type, or usage data for security, analytics, and service improvement purposes. Cookies may be used where permitted by law. You can manage cookie settings through your browser.
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Privacy Officer
We have designated a Privacy Officer who is responsible for our privacy practices and compliance with applicable privacy laws.
All requests for access to your personal information, requests for correction or withdrawal, or any inquiries regarding this Privacy Policy or ULM's handling of your personal information should be directed to:
Brendan Woodfull
BWoodfull@unionlinkmortgage.ca
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Complaints and Questions
If you have questions, concerns or complaints about our privacy practices, please contact our Privacy Officer. We will investigate and respond to all inquiries in a timely manner. If your concern is not resolved, you may contact the appropriate privacy regulator, including the Office of the Privacy Commissioner of Canada, or the privacy commissioners of Alberta or British Columbia, as applicable.
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