WEBSITE PRIVACY POLICY
Last Updated: May 7, 2018
Our Commitment to Privacy: Iron Funding Mortgage Investment Corporation. (“Iron Funding”, “it”, “us” or “we”) is committed to protecting the privacy and confidentiality of personal information in its possession.
This privacy policy is available from our website (“www.ironfunding.ca”) and it explains how personal information is collected, used and disclosed concerning Iron Funding’s customers and other individuals. Iron Funding is committed to collecting, using and disclosing personal information responsibly and in accordance with this privacy policy.
If you do not consent to the collection, use and disclosure of your personal information in accordance with this privacy policy, do not provide Iron Funding with any personal information. It is important to note that some sections of this Website can only be used, and some of Iron Funding’s products and services can only be provided, if Iron Funding receives the appropriate and required personal information. Consequently, should you choose not to provide Iron Funding with the required personal information, Iron Funding may be unable to offer access to this Website, or products and services, to you.
Iron Funding does not knowingly or intentionally collect personal information from visitors who are under the age of eighteen (18). By using this Website or receiving any products of services from us, you represent and warrant that you are over the age of 18 and are lawfully able to accept this Agreement. If you do not have the capacity to enter into a legal agreement in the province, state, territory or country in which you reside, do not access or use the Website or receive any products or services from us.
Accountability: Iron Funding has designated a Privacy Officer who is responsible for the creation, oversight and implementation of this Privacy Policy and procedures to protect personal information, for receiving your privacy-related questions, and for providing you with information about our privacy practices. Our Privacy Officer is also responsible for notifying you of any material changes to our privacy practices, by posting updated information on our Site.
You can contact our Privacy Officer:
Phone: (226) 777-5888
Attention: Privacy Officer
Please contact our Privacy Officer to obtain further information about Iron Funding’s policies and procedures, to seek access to personal information Iron Funding may have about you, or if you have any unresolved inquiries or concerns. Iron Funding will respond to you and try to resolve your concerns. Iron Funding may need to ask you for personal information to verify your identity.
Personal Information: For the purposes of this privacy policy, the term “personal information” means any information that is defined to be personal information under applicable privacy laws. Usually, this refers to any information about an identifiable individual or any information that can be used to identify an individual. As an example, personal information may include any of the following: a person’s name, email address, residential address, telephone number, social media addresses, and in some cases, more sensitive information such as but not limited to gender, demographic information, family status, investment particulars, consumption preferences, business expenditures, credit score, accounting data, social security or social insurance numbers, bank account information, and payment card information.
In most circumstances, personal information does not include the business contact information of a representative of an organization, such as the representative’s name, position or title, business address, business telephone number or business fax number. Publicly available information, such as information in a public directory, is not personal information under this privacy policy.
Purposes: Iron Funding may collect, use or disclose personal information for the purposes identified at the time of collection, as otherwise permitted or required by applicable law, or for any of the following purposes:
- To provide communications, and deliver programs and event information;
- To establish, maintain and manage our relationships with users of the Website;
- To provide products and/or services to users and/or access to Iron Funding’s Website;
- To comply with Iron Funding’s legal obligations and regulatory requirements;
- To provide information to anyone working with or for Iron Funding as needed for the provision of Iron Funding’s products and/or services;
- To develop and manage Iron Funding’s business and operations;
- For billing, accounting and debt collection services relating to Iron Funding’s products and services;
- To distribute publications, invitations, advertising, and other communications that Iron Funding believes may be of interest to Iron Funding’s clients, customers and other individuals;
- To respond to questions and concerns of users;
- To contact users for survey or client satisfaction purposes, or for the purpose of market or other types of research;
- To detect and protect Iron Funding and third parties from error, negligence, breach of contract, fraud, theft or other illegal activity, and which may include sharing personal information with Iron Funding’s insurers;
- To otherwise communicate with Iron Funding’s insurers;
- To generate analytics, improve system design, create benchmarks and conduct trending analyses;
- To comply with any laws, regulation, court orders, subpoenas or other legal process or investigation and to protect ourselves and other individuals from harm;
- To support hosting and backend infrastructures of Iron Funding or of third parties that assist Iron Funding;
- To generate location-based interactions;
- To manage contacts and to manage the sending of messages;
- To undertake registration and authentication of users;
- To monitor system usage, server and software performance;
- To assist you with technical support issues – it is important to note that most technical issues can be resolved without a Iron Funding customer service representative viewing your personal information;
- To assist in due diligence relating to any corporate action such as a financing, merger, amalgamation, sale or divestiture, provided that reasonable safeguards are taken to protect the confidentiality of personal information in our possession;.
- For internal, external and regulatory audit purposes; and
- For any other purpose for which Iron Funding has your
Limiting Collection: Iron Funding collects your personal information in accordance with this privacy policy. Iron Funding will try to limit the collection of your personal information to only the minimum amount of personal information required to fulfill the identified purposes, such as facilitating use of this Website, and provision of any products or services to you. However, in some instances we may provide you with the option of sharing additional personal information that will enhance your use of our Website and any products or services we provide to you.
Limiting Use, Disclosure and Retention: Iron Funding and its staff will use your personal information in accordance with this privacy policy. Iron Funding will not use or disclose personal information for purposes other than the purposes identified herein, or for purposes for which we have obtained your consent elsewhere.
We also ensure that only our employees, or third parties, responsible for the Website operations, or for providing you with any products or services, have physical or technical access to personal information and only where such access is required to perform work authorized by us.
Iron Funding will retain personal information only for the duration of your enrollment as a Iron Funding user unless otherwise required by our obligations to you, to third parties, or by law. Personal information will be retained in fully encrypted, secure and segregated databases. If you choose to withdraw from the services, we will securely destroy your personal information in our possession and control within a reasonable period of time, unless we are required to retain such personal information longer to fulfill our obligations to you, to third parties, or by law.
However, we may retain non-personally identifiable information indefinitely.
We retain all personal information provided by you on secure servers in Canada or in jurisdictions outside of Canada. Some of our third party partners and service providers may store data received from you (including personal information) on servers in Canada or in other jurisdictions outside of Canada. Data, including personal information, stored outside of Canada will be subject to the laws of the jurisdiction in which such data is stored.
By accessing our Website you consent to the storage of your personal information in Canada or outside of Canada and recognize that if your personal information will be subject to the laws of
the jurisdiction in which such data is stored. This consent includes all personal information provided via the Website including any password protected portion of the Website.
If access to our Website or use of any of our products or services are provided to you by one of our third party service providers, the third party service provider may have their own terms of use and privacy policies that will govern your relationship with such third parties. You are responsible for reviewing and agreeing to these terms of use and policies. If you do not agree with these terms of use or privacy policies you should not use the products or services offered by such third party service providers.
When Iron Funding data is viewed via a mobile device, some data is cached in the memory of the device. That data is deleted when the related application is closed and does not persist. If the application is put in the background without closing, the data may remain in the cache. We take no responsibility for any unauthorized viewing of this data by third parties.
When possible, Iron Funding will use non-identifiable, aggregate information (e.g. number of users and transactions) when providing information to any third party.
Consent: Iron Funding takes a consent-based approach to the collection, use and disclosure of personal information. We collect personal information directly from you and may collect personal information about you from other sources, such as websites having links to or from this Website, government ministries, departments or agencies, government registries, investigators, health institutions or organizations, insurance companies or financial institutions. We will only obtain personal information from such organizations (e.g., your bank or other third party service providers) when you provide us with the account numbers, passwords or other credentials required to retrieve the personal information, for the purpose of providing you with use of our Website or use of products or services we provide to you.
We use and disclose the personal information only as described in this policy, in accordance with other consents we receive from you, and in accordance with our Terms of Use.
Privacy legislation requires Iron Funding to obtain the consent of an individual to the collection, use or disclosure of personal information in many circumstances.
By providing your personal information to Iron Funding, you agree that Iron Funding may collect, use and disclose your personal information in accordance with this privacy policy and as otherwise permitted or required by law, and that Iron Funding may access, process and store your personal information in Canada or another jurisdiction.
When Iron Funding receives personal information from you for the purposes of providing you with use of this Website, Iron Funding’s products or services, or for other uses identified herein by Iron Funding, you are providing Iron Funding with consent as follows:
- to allow Iron Funding to deal with that personal information in a reasonable manner;
- to allow Iron Funding to provide your personal information to third parties it engages to provide or support Iron Funding’s Website, or to provide any products or services to you;
- to allow Iron Funding to collect your additional personal information from third party sources when you provide us with information required to retrieve your information from such third party sources;
- to allow Iron Funding to use and store your personal information for the purpose of providing you with the products and services you purchase from Iron Funding and to utilize this Website; and
- to allow Iron Funding to transfer your personal information outside of Canada (whereby your personal information will be treated in accordance with applicable foreign laws) for the purpose of storage and use of your personal information by Iron Funding.
If you need to provide Iron Funding with personal information about other individuals, including but not limited to any of your employees, agents, contractors or representatives, you represent and warrant to Iron Funding that:
- where required by law and prior to your disclosure to Iron Funding, you will obtain the consent of each individual to the collection, use and disclosure by Iron Funding for the specific purpose(s) that the disclosure is made by you; and
- you only collect, use and disclose personal information of each individual in compliance with applicable privacy laws.
Providing Iron Funding with your personal information or the personal information of other individuals is always your choice. When you use this Website, request products and/or services from Iron Funding, utilize Iron Funding’s services, or register with this Website, Iron Funding asks that you provide information that enables Iron Funding to respond to your request and/or provide you with Iron Funding’s products or services. In doing so, you consent to Iron Funding’s collection, use and disclosure to appropriate third parties of such personal information for these purposes.
There are legal exceptions where Iron Funding will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. Some examples of situations where consent is not required include an emergency that threatens the life, health or security of an individual, or if Iron Funding must comply with a court order or governmental order.
If Iron Funding sells its business or merges with another party, your consent will be implied to transfer your information to Iron Funding’s successor for the same purposes as set out in this privacy policy.
Disclosure of personal information: Iron Funding will only disclose your personal information for the purposes set out in this privacy policy.
Iron Funding will never sell your contact details to a third party. Iron Funding does not sell client lists or personal information to others. In providing Iron Funding’s products or services or access to Iron Funding’s Website, Iron Funding may need to disclose the personal information Iron Funding collects to other service providers or agents who perform various functions for Iron Funding, provided such suppliers agree to keep all personal information private, confidential and secure and to use the personal information only to carry out work on Iron Funding’s behalf.
In certain circumstances, Iron Funding may be required to provide personal information to third parties for legal or regulatory purposes. For example, under certain exceptional circumstance Iron Funding may have a legal duty or right to disclose personal information without the individual’s knowledge or consent. Various government agencies such as the Canada Revenue Agency, Human Rights Commission, Ontario Ministry of Finance; Ontario Ministry of Labour, etc. and law enforcement, have the authority to review our files and interview our staff when deemed necessary. These agencies have their own strict privacy obligations.
Privacy and Our Websites: Each time a visitor comes to the Website, Iron Funding’s web server may collect and log certain information in access logs. Such access logs may be kept for a reasonable period of time. Such access logs may include, but not be limited to, information such as the following: your machine’s TCP/IP address, files accessed, the date and time of such access, and other information pertaining to your activities on Iron Funding’s Website and/or webpages linked thereto. These logs are used solely for performance, site administration and security reviews. They are not sold or shared in any way to third party organizations. Iron Funding may use this non-personal information to optimize Iron Funding’s Website, products and/or services.
Iron Funding may, from time to time, use “cookies” solely for security and authentication purposes. Cookies are small pieces of data which are stored on your computer or smart device to allow your Internet browser to remember something about a website and/or services. At your option, you may turn off Iron Funding’s “cookies” using the applicable features contained in your Internet browser; however, doing so may prevent you from accessing all or part of Iron Funding’s Websites, products and/or services. To readjust your Internet browser’s cookies options, refer to the applicable instruction documentation for your particular Internet browser.
Iron Funding may, from time to time, engage third parties to assist with this Website, and such third parties may track your usage, locate your geographic position, collect personal information, send messages to you on behalf of Iron Funding, push notifications to you, and use “cookies”, as discussed herein.
By accessing and browsing Iron Funding’s Website, products and/or service(s), you agree that Iron Funding, or any third party it engages or that assists Iron Funding, may collect, use and disclose any information collected about you through Iron Funding’s Website, products and/or services or that you provide to Iron Funding through Iron Funding’s Website, products and/or services as described in this privacy policy.
Iron Funding’s Website, products and/or service(s) may contain links to other sites and may provide forms on behalf of other organizations. This privacy policy only applies to personal information that we collect, use and disclose. Iron Funding is not responsible or liable for the privacy practices of third parties, including any organizations on the behalf of which Iron Funding provides forms, and Iron Funding strongly recommend that you review a third party’s privacy policy before disclosing any personal information to the third party.
Retention and Destruction of personal information: The amount of time Iron Funding will retain personal information varies, depending on the use of this Website, the products or services Iron Funding has provided, and the nature of the personal information that Iron Funding holds. Iron Funding retains personal information for such period of time as is necessary for Iron Funding to maintain sufficient information so Iron Funding may respond to any issues that arise at a later date or as is required by law.
When personal information is no longer required by Iron Funding or by law, Iron Funding will either convert it into an aggregated non-identifying form or Iron Funding will appropriately destroy or erase the personal information in a manner that is in accordance with Iron Funding’s current policies and procedures.
Safeguards: Iron Funding implements reasonable industry practices appropriate to the sensitivity of your personal information to protect Iron Funding’s systems and personal information under Iron Funding’s control against unauthorized access and use. We use administrative, technical, and physical safeguards to protect your personal information against loss, theft, and unauthorized access, use, disclosure, copying, modification, disposal, or destruction in accordance with applicable legal requirements and industry best practices.
Iron Funding may engage third party external servers as well as other external services, including cloud services and cloud compatible servers, and Iron Funding does not have any control over such external servers or services.
Electronic Communications: Email is frequently Iron Funding’s preferred method of communicating with you and others, and, unless you object, Iron Funding may use unencrypted plain text or html-based emails or messages when communicating with you. These emails or messages, and other electronic means by which Iron Funding may communicate with you, may contain information that is confidential, unless you instruct Iron Funding not to send such information electronically. Iron Funding may communicate with you through other electronic means, in accordance with the contact information you provide to Iron Funding.
While Iron Funding makes every effort to secure all electronic communications within Iron Funding’s control, there are inherent risks involved with exchanging information electronically. For example, such information may be accidentally or deliberately intercepted by third parties. Iron Funding is unable to accept any responsibility or liability for any damages you may suffer as a result of the interception, alteration or misuse of any information during any electronic exchange of such information.
Iron Funding will endeavour to be compliant with Canada’s Anti-Spam laws (“CASL”) in Iron Funding’s commercial electronic communication with you. Should you fail to provide Iron Funding with the requisite consent to send you commercial electronic messages, or withdraw such consent, Iron Funding may be unable to provide, or continue to provide, this Website or some of Iron Funding’s products and/or services that can only be provided if Iron Funding receives appropriate and required personal information. CASL consent can be provided or
withdrawn at: support@● [verify email address]
An unsubscribe link will also be provided in our emails to you.
Keeping Information Accurate / Access and Correction: Iron Funding relies on you to ensure that the personal information you provide to us while using the Website or any products or services that we provide to, relating to yourself or any other individual, is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. You must verify all information created from your use of the services and we recommend that you consult an accounting professional before completing any government or regulatory filing or otherwise relying upon the information, as the use of this information is at your own risk.
You are responsible for ensuring that that the information you have provided is truthful, accurate, reliable and complete.
It is important to Iron Funding that your personal information held by Iron Funding is accurate and complete. Having accurate information about you enables Iron Funding to give you better service. It also helps to ensure the accuracy of the information in our reports, displays, articles and support queries, you can help Iron Funding keep personal information up-to-date by keeping Iron Funding informed of any changes, such as a change of address, telephone number or any other circumstances.
With some exceptions, Iron Funding has the right to access, verify and amend the information Iron Funding has about you after Iron Funding has received your written request and authenticated your identity.
In some situations, Iron Funding may not be able to provide access to certain personal information as the right to access personal information is not absolute. If Iron Funding does not provide you with the requested information, Iron Funding will notify you in writing and explain Iron Funding’s reason(s) for not fulfilling your request.
Despite Iron Funding’s efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect or incomplete, let Iron Funding know and Iron Funding will make the corrections promptly and use every reasonable effort to communicate these changes to other parties who may have inadvertently received incorrect or out-of-date personal information from Iron Funding. Iron Funding will note errors, incomplete information or unresolved differences in information collected in any file it has relating to you.
You agree to indemnify and hold Iron Funding, its affiliates, subsidiaries, partners, service providers, suppliers and contractors and each of their respective officers, directors, agents, and employees, harmless for any loss, cost, complaint, damage, claim or liability whatsoever arising from the collection, use and disclosure of personal information relating to you or any individual that you provide to us, and any personal information relating to you that we obtain from third party sources in accordance with this privacy policy.
Withdrawal of Consent: At any time and without penalty, you can withdraw their consent to Iron Funding’s collection, use and disclosure of your personal information, subject to reasonable notice and any legal and/or contractual restrictions, by emailing us at: support@● [verify email address]
Should you choose to withdraw your consent, Iron Funding may be unable to provide, or continue to provide, this Website or some of Iron Funding’s products and/or services that can only be provided if Iron Funding receives appropriate and required personal information.
Consequently, should you choose not to provide Iron Funding with the required personal information, Iron Funding may be unable to offer this Website and such products and/or services to you.
You may, at any time, ask Iron Funding not to send you further marketing materials about Iron Funding’s products or services or if you do not wish to receive further invitations, you may unsubscribe or ask Iron Funding not to contact you for these purposes.
Withdrawing your consent will not prohibit Iron Funding from undertaking actions that Iron Funding has already taken based on your prior consent.
Openness: Iron Funding makes clear and transparent notice of its privacy practices, and this privacy policy is publicly available on our Website. This privacy policy describes the collection, use, disclosure, and protection of personal information and provides the contact information of our privacy officer.
Iron Funding will advise you at the first reasonable opportunity upon discovering or being advised of an incident whereby your personal information is lost, stolen, accessed, used, disclosed, copied, modified or disposed of by unauthorized persons or in an unauthorized manner.
Privacy Concerns: Iron Funding will respond to questions and concerns relating to Iron Funding’s personal information handling practices and this policy. Please direct such questions and concerns to our privacy officer with the following indication on the envelope, on the letter and/or in the email, as applicable – Attention: Privacy Officer
Individual Access: Upon request, we will inform you if we hold any personal information about you and provide you with access to this information, within a reasonable period of time, and as permitted in accordance with applicable laws. If we have any personal information about you, we will also tell you for what purposes it is used or disclosed, within a reasonable period of time, and as permitted in accordance with applicable laws.
You have a right to update any personal information that we hold about you. Should you wish to
see the full contents of your personal information file, you must make a formal written request and mail it to our privacy officer with the following indication on the envelope and the letter – Attention: Privacy Officer. We will respond to you within a reasonable period of time, or let you know why there might be a delay.
Changes to this Privacy Policy: This privacy policy is effective as of May 7, 2018. Iron Funding reserves the right to change this privacy policy, and any of Iron Funding’s policies and procedures concerning Iron Funding’s practices for handling personal information, at any time and without any prior notice. If Iron Funding has modified or amended our privacy policy, Iron Funding will post the most current version on Iron Funding’s Website. Any changes that are made to this privacy policy will apply to both any personal information that Iron Funding holds prior to the effective date of the amended privacy policy and any personal information that Iron Funding collects on or after such effective date.
Successors and Assigns: Iron Funding’s successors and assigns may collect, use and disclose your personal information for substantially similar purposes as described in this privacy policy.
© Iron Funding Mortgage Investment Corporation, 2018.