PRIVACY POLICY

1. Who we are

HB Mortgage Centre is a licensed Ontario mortgage brokerage operating under FSRA Brokerage Licence #13449, regulated by the Financial Services Regulatory Authority of Ontario (FSRA) under the Mortgage Brokerages, Lenders and Administrators Act, 2006 (MBLAA).

Our registered contact: Phone: (289) 236-3102
Website: privatemortgage.hbmortgagecenter.com

2. What this policy covers

This Privacy Policy explains how HB Mortgage Centre collects, uses, stores, discloses, and protects your personal information when you use our website, complete our inquiry form, or communicate with us by phone, text, or email. It applies to all personal information we handle in connection with our mortgage brokerage services.

3. Applicable law

We comply with the following Canadian legislation:

• Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c. 5
• Canada's Anti-Spam Legislation (CASL), S.C. 2010, c. 23
• Mortgage Brokerages, Lenders and Administrators Act, 2006 (MBLAA), S.O. 2006, c. 29
• Ontario Regulation 188/08 and Ontario Regulation 191/08 under the MBLAA
• Financial Services Regulatory Authority of Ontario (FSRA) guidance on mortgage brokerage advertising and disclosure

4. Information we collect

When you submit an inquiry through our website or contact us directly, we may collect:

• Full name
• Phone number (mobile and/or landline)
• Email address
• Property address or general location (city/region)
• Estimated property value
• Estimated current mortgage balance
• Loan purpose (refinance, purchase, debt consolidation, bridge financing, other)
• Credit situation (self-described range)
• Preferred contact time
• Any additional information you voluntarily provide during conversations with our brokers

We also collect non-personal technical information through our website including browser type, device type, pages visited, time on site, and referral source. This is used for analytics and advertising optimization purposes only and is not linked to your identity without your consent.

5. How we use your information

We use your personal information to:

• Assess your mortgage inquiry and determine potential financing options
• Contact you by phone, text message, or email to discuss your situation and available options
• Match your file with appropriate private lenders or mortgage investment corporations in our network
• Prepare and deliver mortgage suitability assessments and borrower disclosures as required under MBLAA
• Comply with our regulatory obligations under FSRA, MBLAA, and applicable Ontario legislation
• Improve our services and marketing communications with your consent

6. Communication consent (CASL)

By submitting an inquiry through our website, you expressly consent to HB Mortgage Centre contacting you by phone, text message, and email regarding your mortgage inquiry and related options.

This constitutes express consent under Canada's Anti-Spam Legislation (CASL) for the purposes of electronic commercial messages. Your consent covers:

• Calls and text messages to the phone number you provided
• Emails to the email address you provided
• Follow-up communications related to your inquiry for a period of up to 24 months from your last interaction with us, unless you withdraw consent earlier

You may withdraw your consent at any time by:

• Replying STOP to any text message we send you
• Clicking the unsubscribe link in any email we send you
• Calling us at (289) 236-3102 and requesting removal
• Emailing us with an unsubscribe request

Withdrawal of consent will be processed within 10 business days as required under CASL. Withdrawing consent does not affect the lawfulness of any communications sent prior to withdrawal.

7. Sharing your information

We do not sell your personal information to third parties under any circumstances.

We may share your information with:

• Private lenders, Mortgage Investment Corporations (MICs), and other funding sources in our network, solely for the purpose of assessing and arranging mortgage financing on your behalf
• Independent legal counsel as required under the Ontario Two Lawyer Rule for private mortgage transactions exceeding $75,000
• Property appraisal professionals retained to assess collateral value
• Our technology and CRM service providers who process data on our behalf under confidentiality agreements
• FSRA or other regulatory authorities if required by law, court order, or regulatory investigation

All third parties who receive your information are required to handle it in accordance with applicable Canadian privacy law. We do not share your information for marketing purposes with any party outside HB Mortgage Centre.

8. Digital advertising and tracking technologies

We use third-party digital advertising platforms to reach potential clients. If you arrived at our website through any paid advertisement, the following applies to each platform we use.

9. Data retention

We retain your personal information for a minimum of six years from the date of your last transaction or inquiry, as required under MBLAA and Ontario Regulation 188/08. After this period, personal data is securely deleted or anonymized unless we are required by law to retain it longer.

Mortgage suitability assessments, borrower disclosures, and deal documentation are retained for the period required by FSRA regulatory standards.

10. Data security

We protect your personal information using industry-standard security measures including:

• 256-bit SSL/TLS encryption for all data transmitted through our website
• Encrypted storage for all personal and financial data
• Access controls limiting data access to authorized personnel only
• Secure transmission protocols for data shared with lenders and service providers

No method of electronic transmission or storage is 100% secure. While we implement commercially reasonable safeguards, we cannot guarantee absolute security.

11. Your rights under PIPEDA

You have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Withdraw consent for the collection, use, or disclosure of your information (subject to legal and regulatory obligations)
• Request deletion of your information where no legal retention obligation applies
• File a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca if you believe your privacy rights have been violated

To exercise any of these rights, contact us at (289) 236-3102 or through our website. We will respond within 30 days.

12. Cookies and tracking

Our website uses cookies and similar tracking technologies for the following purposes:

• Essential cookies: required for the website to function (form submissions, session management)
• Analytics cookies: used to understand how visitors use our site (Google Analytics or similar)
• Advertising cookies: used to measure the effectiveness of our Meta advertising campaigns

You may disable non-essential cookies through your browser settings. Disabling cookies will not prevent you from using our website but may affect certain functionality.

13. Children's privacy

Our services are intended for adults aged 18 and older who own or are purchasing property. We do not knowingly collect personal information from anyone under the age of 18.

14. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The effective date at the top of this document will be updated accordingly. Continued use of our website after any update constitutes acceptance of the revised policy.

15. Contact us

Regulatory notice

HB Mortgage Centre is licensed and regulated by the Financial Services Regulatory Authority of Ontario (FSRA) under the Mortgage Brokerages, Lenders and Administrators Act, 2006. Hardeep Batoo serves as Principal Broker, FSRA Brokerage Licence #13449. All mortgage brokerage activities are conducted in compliance with applicable Ontario legislation and FSRA regulatory standards.