Harbour Mortgage Corp., Harbour Real Estate Investments Inc., HMT Holdings Inc., and their respective affiliates and associated entities (collectively “Harbour”, “we”, “our”, “us”) recognizes the importance of your right to privacy and wants you to be familiar with how we collect, use and disclose any personal information that individually identifies you and our commitment to meet our obligations under applicable Canadian privacy laws.
1. What Personal Information do we collect?
Personal information means any information about an identifiable individual. Anonymous data means data that is not associated with or linked to any individual’s personal information or will not easily permit the identification of individuals (“Anonymous Data”). We do not consider personal information to include Anonymous Data.
We collect your personal information about you when you provide it to us or use our or Services. We may also collect information about you from certain third parties in order for us to be able to provide and facilitate the Services to you. In most instances, you will decide what information you provide us. In certain instances, if you choose not to provide us with personal information, you may not be able to fully utilize our Site or Services.
At Harbour, we may collect personal information from you such as your name, address, telephone number, email address, and any other information that may be provided by you through your interactions with Harbour.
2. Purposes for Collecting Your Personal Information
We collect, use and disclose your personal information in order to provide you with our Services. We also collect, use and disclose your personal information to comply with legal and regulatory requirements and as otherwise may be permitted or required by applicable laws. We will only use the personal information that we collect for the purposes for which it was collected. We collect your personal information for the following purposes and in accordance with applicable laws:
- To present our Site and its contents to you;
- To provide you with our Services;
- To provide you with information, products, or Services that you request from us;
- To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it;
- To improve our Site or Services, marketing, or customer relationships and experiences;
- To verify and confirm your identity;
- To establish and maintain commercial relations with you, including responding to your questions regarding our Services;
- To respond to questions that you send by email or through our Site;
- To customize the appearance of the Site displayed to you;
- To meet any legal or regulatory requirements.
3. When Do We Collect Personal Information?
We may collect your personal information when you voluntarily provide it to us by registering for and using our Services. For example, we may ask you to provide personal information if you:
- Use our Services;
- Correspond with us by email or phone;
- Otherwise participate in features of our Site and our Services that ask for personal information
4. Limiting Collection of Personal Information
5. Consent, Use Disclosure and Retention of Personal Information
Depending on the sensitivity of the personal information, your consent to our collection, use and disclosure of personal information may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction.
We may generate Anonymous Data from personal information collected through the Site and Services by removing information that makes the data personally identifiable to an individual. Such Anonymous Data includes, but is not limited to, information we collect from your use of our Site and Services. We may use this Anonymous Data and aggregated data for any reasonable purpose subject to applicable laws. We do not disclose this data to third parties.
We retain your personal information only for as long as we need it to fulfill the purposes for which it was collected and to comply with our legal obligations.
We may also use and disclose your personal information to service providers, data processors and other third parties (“Third Parties”) under the following limited circumstances:
- When necessary to protect (i) our safety, property or other rights; (ii) our representatives, customers and users of the Site and stakeholders; (iii) to conduct investigations of possible breaches of law, including, including to detect and prevent fraud;
- To identify, contract or bring legal action against someone who may be violating an agreement that they have with us;
- To investigate breaches of security safeguards or cooperate with government or regulatory authorities pursuant to a legal matter;
- On the sale of our business where personal information may be provided to third parties in connection with a prospective or completed business transaction, including a sale or merger (including transfers made as part of bankruptcy proceedings or insolvency) involving all or a part of Harbour or as a part of a corporate reorganization or stock sale or additional or other changes in corporate control;
- With your consent; or
- As otherwise required or permitted by law.
We may also, from time to time, as part of our due diligence process, collect personal information about you from telephone calls, application forms or contracts, face-to-face meetings, emails or other forms of communication, past dealings you may have had with us, credit reporting agencies, current or previous lenders or bankers or mutually known parties such as brokers or intermediaries. This allows us, and any credit bureau, service provider, person or organization to whom we may disclose your personal information, to verify your identity, understand your needs, assess your creditworthiness and financial status, take a security interest, obtain automatic bank withdrawals, comply with tax, regulatory, contractual and other legal requirements, and if required, to assist with enforcement and collection of the loan.
If we syndicate or assign your mortgage or loan, or otherwise sell, merge or amalgamate some or all of our business with other entities, we may release the personal information we hold about you to the prospective investor, purchaser or assignee as part of the due diligence process, and when the transaction is completed.
6. Data Transfers
Your personal information may be collected, used, processed, transferred, and retained in multiple countries including Canada and the United States which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. Additionally and as discussed above, we may also engage Third Parties to perform certain services on our behalf and to otherwise provide the Services. These Third Parties may store, process and transfer personal information on servers located outside of Canada in jurisdictions whose data protection laws may differ from those of Canada, such as the United States of America. As a result, personal information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to the laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our Third Parties to maintain protections on personal information that are equivalent to those that apply in Canada.
7. Links to Other Sites
8. Cookies, Web Beacons and Other Similar Technology
As you interact with this Site and Services, we may use automatic data collection technology and services that record and collect information that identifies your computer, tracks your use of this Site and Services and collects certain other information about you and your surfing habits. These data collection technology and services allows us to store and manage user preferences, enable content, deliver targeted advertising and collect usage data and analytics to ensure the smooth functioning of our Site on your computer or device. These data collection technology may include cookies, web beacons and other similar devices on this Site and Services to enhance functionality and navigation for our visitors. Cookies and other tracking technologies are commonly used by websites and apps through which information is collected about your online activities.
A cookie is a small data file that is placed on your computer or other electronic device so that your device will “remember” information when you visit a site.
Web beacons and tags are small strings of code that are used in conjunction with a cookie and allow us to record activity on our Site. Internet tags, graphic tags and similar web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies.
We may use web beacons on this Site to count users and to recognize users by accessing our cookies. Being able to access our cookies allows us to personalize this Site and improve your experience at our Site. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. Information tracked through these mechanisms includes, but is not limited to: (i) your IP address; (ii) the type of web browser and operating system being used; (iii) the pages of the Site a user visits; and (iv) other sites a user visited before visiting our Site. Web beacons may also be used to deliver interest-based advertising to you.
You can set your internet browser up so that you are notified when cookies are stored, you can decide in each individual case whether you want to accept cookies, or you can refuse to accept any cookies. However, if you do not accept cookies, you may be restricted in how you are able to use our Site. You can delete cookies that are already stored on your hard disk at any time. You will find more details on how to do this in the operating guide for your Internet browser program.
9. Third Party Analytics
10. How We Protect Your Information
We maintain reasonable technical, physical and organizational security safeguards to protect your personal information against loss, theft, and unauthorized access. Any personal information that you provide to us is exchanged on a secured server. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.
We take reasonable steps to verify your identity before granting you access to your information, however, you are solely responsible for maintaining the secrecy of your username, password and any other information. We also take reasonable steps to ensure that our employees are aware of the importance of maintaining the confidentiality of personal information and that unauthorized persons do not gain access to personal information that we have disposed of or destroyed.
11. Children Under 13
We do not knowingly solicit, collect, or store any personally identifiable information from anyone under the age of 13. Children under the age of 13 are not allowed to create an account or otherwise use the Services. In the event we learn that we collected personal information from a child under the age of 13, we will delete that information as quickly as possible. If parents or guardians believe that we have unintentionally collected their children’s personal information, they may request the deletion of the information by contacting us at firstname.lastname@example.org.
12. Individual Access and Accuracy of Personal Information
You may request access to your personal information which we may hold by contacting us at the contact information set forth below, and we will respond within the time periods provided for under applicable laws. We will need to verify your identity before providing you with the personal information we hold about you. There is no cost for such access request unless you require copies of records. We may not be able to provide you with access to your personal information if the information cannot be separated from the personal information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide you with access to your personal information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so.
You may request to update and change your personal information at the contact information set forth below. We will endeavor to correct or complete any personal information which you advise us is inaccurate or incomplete. Where appropriate, the amended information will be transmitted to third parties having access to such information.
13. Electronic Communications
When you sign up for a Harbour account and create a profile, or otherwise sign-up to receive information regarding our developments or related products and services, we collect your contact information such as your name, phone number, mailing addresses and email address. If you opt in to receiving our communications, we will use this information to send you communications based on your expressed interests by mail or email.
You will always have the opportunity to unsubscribe from receiving any of our e-mail or other communications at any time by contacting us at 416-361-3315 or by email at email@example.com and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us. We provide an on-going opportunity to unsubscribe or opt-out of contact by us as described in the footer of all emails, or at firstname.lastname@example.org.
16. How to Contact Us
- See your personal information that you have already sent us so that you can correct, update or delete it from our files;
- Ask that we not send you electronic communications or otherwise contact you; or