Mortgage Application Privacy

YOUR PERSONAL AND FINANCIAL INFORMATION IS PROTECTED WITH US
MB Direct is extremely dedicated to your right to privacy and takes your privacy very seriously. Our company has very strict privacy policies and we make every effort to keep your personal and financial information safe and protected at all times.

PRIVACY POLICIES

1. MB Direct is accountable for the protection of clients` personal information. While senior management is ultimately accountable for the protection of personal information, the day-to-day monitoring for compliance may be delegated to other staff.

2. MB Direct is committed to ensuring that the appropriate security measures are employed in the transfer of sensitive information. However, when using e-mail or wireless communication, MB Direct advises clients that complete confidentiality and security are not assured.

3. MB Direct is not accountable for any damages suffered when a client transmits personal information through e-mail or wireless communication or when MB Direct transmits information at the request of the client.

4. MB Direct has developed policies and procedures to: protect personal information; receive and respond to complaints and inquiries; train staff regarding the policies and procedures; communicate the policies and procedures to our clients.

5. MB Direct collects client personal information for the following reasons only:

To provide financial services;
To understand their clients` financial needs;
To broker and administer loan agreements;
To develop, manage and deliver products and services to clients;
To develop and deliver marketing and promotional offers to clients;
To determine client eligibility for different products and services;
To ensure that clients receive a high standard of service;
To meet regulatory requirements;
To manage and transfer the assets and liabilities of MB Direct and those assets under its administration; and
To verify client`s identity.

MB Direct will only collect personal information for the purposes identified. MB Direct will use methods that are lawful and will not collect information indiscriminately. MB Direct will not use personal information for any additional purpose unless MB Direct seeks client consent to do so.

6. MB Direct will obtain client consent to collect, use or disclose any personal information except where detailed in this policy. MB Direct will make reasonable efforts to ensure that clients understand how their personal information will be used and disclosed.

7. A client`s consent can be express, implied, or given through an authorized representative such as a lawyer, agent or broker. Consent may be given orally, in writing, or electronically. For example, depending on the sensitivity of the information, consent can be expressed over the telephone when information is being collected; electronically when submitting an agreement, application, or other information; in writing when signing an agreement or application form. Implied consent exists when MB Direct can reasonably infer consent based upon the action or inaction of the client.

8. MB Direct, however, may collect, use or disclose personal information without the client`s knowledge or consent in exceptional circumstances:

When such collection, use or disclosure is permitted or required by law
When certain information is publicly available
When we require legal advice from a lawyer
When we need to collect a debt from a client
When we need to deal with an anticipated breach of law
When potential investors/stakeholders wish to ensure the quality and characteristics of an investment.

9. Subject to contractual or legal arrangements, clients may withdraw or refuse consent provided that MB Direct is given reasonable notice. MB Direct may decline to deal with a client or person who will not consent to the use of such information.

10. MB Direct may periodically use client personal information to conduct client surveys in order to enhance our provision of services or products. If an outside body is employed to conduct research on behalf of MB Direct, or provide other services that require access to client information, MB Direct will ensure that appropriate security undertakings, such as confidentiality clauses in contractual arrangements, are employed to protect the transfer and use of personal information.

11. MB Direct will retain client personal information only as long as necessary or expected to be necessary for the identified purposes, or as required by legislation.

12. MB Direct may disclose personal information related to a financial asset of MB Direct along with transfer of the financial asset.

13. MB Direct will make reasonable efforts to ensure that client personal information is as accurate. In some cases, MB Direct relies on its clients to ensure that certain information, such as the client`s address or telephone number, is current, complete, and accurate.

14. MB Direct will not routinely update information unless it is necessary to fulfill the purposes for which it was collected or if it is required to maintain an active account.

15. MB Direct is committed to the safekeeping of client personal information in order to prevent its loss, theft, unauthorized access, disclosure, duplication, use, or modification, and will employ appropriate security measures to protect the information. The measures may include, for example, the physical security of offices and data, and electronic security measures such as passwords and encryption where appropriate.

16. MB Direct will use appropriate security measures when disposing of client personal information.

17. The development of MB Direct`s policies and procedures for the protection of personal information is an ongoing process. Changes in technology necessitate that MB Direct continually develops, updates, and reviews information protection guidelines and controls to ensure ongoing information security.

18. MB Direct will make the following information available:

The name, title and address of the person accountable for the policies and procedures and to whom complaints or inquiries can be forwarded;
A description of the type of personal information held by MB Direct, including a general account of its use;
A copy of any brochures or other information that explain the policies and procedures; and
An explanation of what personal information is made available to affiliated companies or investors.

19. Clients have a right to access their personal information held by MB Direct. Upon request, MB Direct will, within a reasonable time period, tell the client what personal information it has, what it is being used for, and to whom it has been disclosed if applicable and within the time period for which records are available.

20. Clients may be asked to be specific about the information they would like to access and to submit their request in writing to MB Direct.

21. Clients will be required to provide personal information to identify themselves to enable MB Direct to provide an account of the existence, use, and disclosure of personal information.

22. MB Direct will make the information available within 30 days, or provide written notice of extension where additional time is required to fulfill the request. When information is not provided within 30 days of the request, MB Direct will, no later than 30 days after the date of the request, send a notice of extension to the client, advising of the new time limit, the reasons for extending the time limit and of the right of the client to make a complaint regarding the extension.

23. If a request is refused, MB Direct will notify the client in writing, documenting the reasons for refusal and resources for redress available to the client.

24. The information will be made available at a cost that will vary with the type and amount of information requested. Where the client will incur a cost, MB Direct will inform the client of the cost and request further direction from the client on whether or not MB Direct should proceed with the request.

25. In certain situations, MB Direct may not be able to provide access to any or all personal information about a client. In such cases, MB Direct will explain the reasons it will not provide the requested information, and identify resources for recourse available to the client. The reasons for not providing information may include that it is unreasonably costly to provide, information that would threaten the life or security of another individual, information generated in a formal dispute resolution process, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

26. If the information is demonstrated to be inaccurate or incomplete, MB Direct will amend the information as required. Where appropriate, MB Direct will transmit the amended information to Third Parties having access to the information in question.

27. Clients are to direct any complaints, concerns or questions regarding this privacy policy in writing to the Compliance Officer.

28. Clients may withdraw consent at any time, subject to legal or contractual restrictions, provided that reasonable notice of withdrawal of consent is given to the MB Direct. On receipt of notice of withdrawal of consent, MB Direct will inform the individual of the likely consequences of the withdrawal of consent, which may include the inability of MB Direct to provide certain products or services, if the information is necessary to provide the products and services.

29. To improve the usability of our website at www.mbdirect.ca, we capture information about how users interact with our site and what pages they visit. No personal information is collected as part of this process. The data we collect is used internally to better understand and support our users.

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