1. Authority & Collection of Information
In accordance with the Mortgage Brokerages, Lenders and Administrators Act (MBLAA) and PIPEDA, we collect information necessary to assess your mortgage suitability and satisfy federal FINTRAC (Know Your Client) requirements. This includes:
- Identification: Government-issued ID, SIN (for credit adjudication), and employment verification.
- Financial Data: Credit reports, bank statements, and tax assessments (NOA).
- Communication & Video: We record video consultations. These recordings form part of your “Client File” and are used to verify the suitability of the mortgage products recommended and to ensure accurate records of disclosures made to you.
2. Data in Motion: Security Standards
We understand that mortgage data is constantly moving between you, our team, and lenders.
- Secure Document Uploads: All sensitive documentation must be uploaded via our SOC2-compliant secure portal. We do not accept or store sensitive financial documents via unencrypted email.
- Encryption Protocols: All data, including video recordings, is encrypted at rest and in transit using industry-standard AES-256 encryption.
- Lender Disclosure: We only share your information with lenders and service providers (appraisers, lawyers) who are necessary to complete your transaction.
3. FSRA-Mandated Record Retention
Per FSRA Ontario Regulation 188/08, we are legally required to maintain a complete record of your transaction.
- The 6-Year Rule: All records (including video recordings, applications, and correspondence) must be retained for at least six (6) years after the mortgage term expires or the transaction is completed.
- Unfunded Applications: If your mortgage does not close, we are still required to keep your data for six (6) years from the date the record was created.
4. Video Meeting Protocol & Consent
Your privacy during virtual consultations is paramount:
- Explicit Consent: By participating in a video call with our agents, you provide express consent for the recording of the session for the purposes of accuracy and compliance.
- Storage: Recordings are stored on secured, Canadian-resident servers (where possible) and are not shared with third-party marketers.
5. Your Rights as a Consumer
Under Ontario law, you have the right to:
- Access your file: You may request to see the information we hold about you.
- Correct inaccuracies: We must ensure your financial profile is accurate before submission to lenders.
- Withdraw Consent: You may withdraw consent for us to use your data at any time (subject to our legal obligations to retain records for FSRA and FINTRAC auditing).
6. This Website & Third-Party Services
The sections above describe your Client File. This section describes thefinancialcollective.ca itself, and what happens when you use it.
- Enquiry Forms: When you send a message through this website, what you enter — your name, email address, phone number, and what you tell us about your enquiry — is submitted into our Zoho CRM system and used to respond to you. It is held to the standards set out in this policy. You are not added to any mailing list unless you ask to be. Our form provider also records that a form was completed, so that we can tell a genuine enquiry from an incomplete one.
- Booking: Appointments are arranged through Zoho Bookings, which collects the contact details you enter in order to confirm the appointment with you.
- Embedded Tools: Some pages load content supplied by others — the mortgage calculators and our client review feed. When that content loads, your browser contacts those providers directly and they receive your IP address and browser information. The calculators load only when you open one.
- Hosting & Fonts: This site is hosted by Vercel and uses Google Fonts. Both receive your IP address as an ordinary part of delivering the page to you.
- Links Out: Where we link to a service run by someone else — our property monitoring partner, the podcast, or The TFC App — you leave this website, and that provider’s own privacy policy applies from that point.
- Cookies & Tracking: We do not set advertising cookies and we do not run advertising pixels or third-party analytics on this site. The services named above may set their own cookies when their content loads.
7. Privacy Officer Contact
The Financial Collective has appointed a Privacy Lead to oversee our compliance with FSRA and PIPEDA standards. Privacy Officer:
