Privacy Policy

1. PREAMBLE

1. This Policy explains the principles Kristina Lacerte-Carboni, mortgage broker intern, operating via Hypotheca, and her partners implement to collect, use, disclose, retain, and destroy personal information in the course of mortgage brokerage services in Canada (Montreal and Lanaudière).
2. It outlines the roles and responsibilities of the Privacy Access and Protection Officer (the “PRP Officer”) and the rights of individuals.
3. It applies to all personal information of clients, suppliers, staff, and partners.

2. CONSENT

By communicating with Kristina Lacerte-Carboni and Hypotheca, you consent to the collection, use, disclosure, retention, and destruction of your personal information in accordance with this Policy and applicable laws (PIPEDA, Quebec Law 25).

3. RESPONSIBILITIES OF THE FIRM AND THE PRP OFFICER

1. Hypotheca acts as the mortgage brokerage firm and Kristina Lacerte-Carboni acts as a supervised mortgage broker. The PRP Officer ensures compliance with this policy and manages privacy incidents.
2. Security measures appropriate to the sensitivity of the information are in place to protect data.
3. The PRP Officer may include privacy impact assessments and coordinate the handling of complaints.

4. CHANGES TO THE POLICY

Hypotheca may modify this Policy at any time. If changes affect consent, new consent may be required.

5. INFORMATION WE COLLECT

Data collected may include, but is not limited to:

1. Contact details (name, address, phone, email)
2. Financial and tax information relevant to mortgage file evaluation
3. Personal information related to residence and the contemplated property
4. Professional information and relevant occupational data
5. Documentation provided by the client (income, marital status, etc.)

7. ACCESSIBILITY AND RECTIFICATION

You may access your personal information held, request correction or updating when necessary, in accordance with the law.

8. PURPOSES OF COLLECTION

The information is used to:

1. Assess and obtain mortgage pre-approvals via Hypotheca tools
2. Manage renewals and refinancings
3. Communicate and provide personalized support
4. Establish and administer client files and brokerage services

9. SECURITY MEASURES

1. Restricted access to personal information
2. Technical measures (encryption, TLS, secure backups) and organizational measures
3. Secure destruction of documents when required or permitted by law

10. DISCLOSURE TO THIRD PARTIES

1. Information may be disclosed to third parties as part of services (lenders, professional partners, technical providers and cloud solutions) under contract to perform mortgage brokerage services
2. These third parties must respect data confidentiality and security and may use the data only for the agreed purposes

11. WITHDRAWAL OF CONSENT

You may withdraw your consent at any time where legal grounds allow, which may limit or suspend certain services.

12. DESTRUCTION OR ANONYMIZATION

Collected information will be destroyed or anonymized when no longer needed for retention or required by law.

13. PERSONAL INFORMATION PORTABILITY

Upon request, you may receive certain personal information in a structured, readable format or have it transferred to a third party, subject to legal limits.

14. RECORD

Hypotheca maintains a record of incidents that could affect confidentiality and informs individuals in the event of a major incident.

15. PRIVACY IMPACT ASSESSMENT

Privacy impact assessments (PIAs) may be conducted when necessary, in collaboration with the PRP Officer, depending on data sensitivity and processing purposes.

16. COMPLAINT AND PROCESSING

1. Any concerned person may file a complaint in writing with the PRP Officer. The complaint will be handled promptly and diligently.
2. For information, contact the PRP Officer:

17. COOKIES AND TRACKING TECHNOLOGIES

1. Hypotheca uses cookies and similar technologies for site operation, analytics, and personalization.
2. Cookies are categorized: essential, performance, functionality, and marketing (with consent where required).
3. You can manage preferences via the consent banner or your browser settings.

18. ANALYTICS TOOLS

1. We may use tools such as Google Analytics to understand site usage. Data is anonymized and retention periods vary by service.

19. ONLINE ADVERTISING

1. Advertising campaigns may use remarketing and advertising cookies on partner platforms.
2. You can manage preferences via each platform's settings.

20. PROFESSIONAL TOOLS

1. Tools and platforms used in mortgage brokerage (e.g., case management systems, cloud services) may process personal data and include security measures.

21. PREFERENCES MANAGEMENT

1. You can manage your communication and tracking preferences via the options provided in our communications and on the site.

22. NEWSLETTERS AND ELECTRONIC COMMUNICATIONS

1. Newsletter subscriptions: collection of email address and name (optional), with opt-in and unsubscribe options.

23. OUTBOUND MARKETING

1. Outbound communications comply with anti-spam laws and consent-based contact choices.

24. LEGAL BASIS FOR MARKETING

1. Explicit consent for newsletters; legitimate interest or existing contractual relationship for professional communications, all compliant with PIPEDA and Quebec Law 25.