Privacy Policy

Mortgage Intelligence - Smart Debt Mortgages Inc. (“Mortgage Intelligence - Smart Debt Mortgages”) helps customers find the most suitable mortgage, loan or credit facility, and/or other related products and services like insurance that we may offer. Mortgage Intelligence - Smart Debt Mortgages is a member of a group which includes Invis, Mortgage Alliance, Multi-Prêts, and other affiliated entities (hereinafter, the “M3 Mortgage Group”).

At Mortgage Intelligence - Smart Debt Mortgages, we know that the protection of your privacy is important to you. For this reason, we have taken steps to ensure that any personal information that you provide to Mortgage Intelligence - Smart Debt Mortgages is protected by a range of robust business procedures and rigorous security safeguards to ensure that your information is kept confidential and used only for the purposes detailed in this privacy policy. This privacy policy is intended to establish responsible and transparent practices for the management of personal information and to satisfy the requirements of rules established by the Personal Information Protection and Electronic Documents Act (PIPEDA), and similar provincial laws from Quebec, Alberta and B.C.

Application and Scope

This privacy policy generally applies to any personal information (as defined below in the section entitled Definition of Personal Information) collected or generated by Mortgage Intelligence - Smart Debt Mortgages, its brokers or anyone acting as an agent on our behalf (“authorized agent”), from or about its customers and other individuals with whom it deals, which may include potential customers as well as any other additional person named on an account, in any form. At any time that you do business with Mortgage Intelligence - Smart Debt Mortgages, and/or an entity within the M3 Mortgage Group, participate in a contest or promotion run by Mortgage Intelligence - Smart Debt Mortgages, a Mortgage Intelligence - Smart Debt Mortgages broker or with an authorized agent, or interact with us in any manner, you are protected by the rights and safeguards contained in this privacy policy and you explicitly agree to its terms.

This privacy policy also governs personal information collected about Mortgage Intelligence - Smart Debt Mortgages’s website users and explains how we use and disclose personal information that we collect from users who visit our website and otherwise interact with us through www.migroup.ca (“website”). It also explains how we use cookies and similar technologies.

Definition of Personal information

When used in this privacy policy, personal information means “any information about an identifiable individual”. This may include, for example, your name, contact information, email address, information relating to your account with us, including your identity and the mortgage you take out, as well as your credit and banking information, billing records and any complaints documented in a file. It may also include other types of more technical information when you interact with us through our website, when this information can identify you as an individual. Personal information that is aggregated and cannot be associated with an identifiable individual is not considered to be personal information.

Collection and Use of Personal Information

We collect most of our information about you directly from you, with your consent.

We usually collect your name, address, phone number(s), email address, occupation, employer’s name, birth date, annual income, net worth, assets, liabilities, credit history, investment objectives, banking information, as well as other account and payment information, including information pertaining to your use of our products and services when you register to Invis services. We may also collect other information such as your social insurance number, driver’s license or passport number, when required and/or authorized by law, for instance to fulfill regulatory and other governmental obligations and to distinguish you from other clients with similar names.

We may also obtain information about you from third parties, with your consent. For example, for credit evaluation purposes, we may need to determine your creditworthiness through contact with an independent credit reporting agency or another source, which may include account information. Mortgage Intelligence - Smart Debt Mortgages uses this information to help determine the product or service that is suitable to your mortgage needs. We may also collect personal information from other third parties, such as your spouse, if you are applying for certain products and services, and information about beneficial owners, intermediaries and other parties.

Mortgage Intelligence - Smart Debt Mortgages generally collects personal information from or about its customers and other individuals with whom it deals for the following purposes:

If you have applied for employment with Mortgage Intelligence - Smart Debt Mortgages, the personal information submitted with your job application will be used for recruitment and other customary human resources purposes. For example, we may send you information about new job opportunities within Mortgage Intelligence - Smart Debt Mortgages as well as other career development resources.

Unless required or authorized by law, Mortgage Intelligence - Smart Debt Mortgages will not collect or use personal information for any other or new purpose without obtaining further consent. For details on the type of information that we collect via our website and on how we use and share this information, please refer to the Website section of this Privacy Policy.

Mortgage Intelligence - Smart Debt Mortgages offers you the opportunity to use simulators. These simulators are designed to collect information about you or your financial situation. The details are then used to establish your type of profile with a view to helping you choose the most suitable product for your particular needs.

Your Consent

Mortgage Intelligence - Smart Debt Mortgages obtains consent from the individuals concerned for the collection, use or disclosure of personal information through various means. The most common method we use to obtain a customer’s consent is by way of the customer’s consent as confirmed by consent forms. Where practicable, we may also obtain a customer’s consent through electronic communications or other written documentation.

In general, by requesting Mortgage Intelligence - Smart Debt Mortgages products and services and/or submitting information to us in connection with using Mortgage Intelligence - Smart Debt Mortgages products and services, you are providing your consent to the collection, use and disclosure of personal information as set out in this privacy policy and in the Mortgage Intelligence - Smart Debt Mortgages contractual documents. Moreover, by visiting, interacting with and/or using our websites, you agree to benefit from, be bound by, the terms and conditions of this privacy policy.

In certain circumstances, personal information may be collected, used or disclosed without consent. These exceptional circumstances may include:

For more information on how Mortgage Intelligence - Smart Debt Mortgages may share your personal information, please refer to section Sharing of Personal Information of this Privacy Policy.

Right to Withdraw Consent

Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent us from providing you, or continuing to provide you, with Mortgage Intelligence - Smart Debt Mortgages’s products and services or information that may be of value to you. You may also withdraw your consent as follows:

For information on how you can limit the type of information that we collect, use or share about you when you visit and/or use our website, please refer to the Website section of this privacy policy.

Sharing of Personal Information

Your information may be made available by Mortgage Intelligence - Smart Debt Mortgages within the M3 Mortgage Group and to authorized agents or service providers to fulfill the purposes for which it has been collected or as set forth in this privacy policy. Mortgage Intelligence - Smart Debt Mortgages will not sell, rent or trade your personal information to any third party. However, we may share your personal information when authorized by law or as follows:

For information on how you can limit the type of information that we collect, use or share about you when you visit and/or use our website, please refer to the Website section of this Privacy Policy.

Business Analytics

We may share aggregated customers and/or website users’ information with our partners or entities within the M3 Mortgage Group. This information does not allow identifying individual customers nor users, and is only used to provide our partners a better understanding of the general profile of customers of our products and/or services and users of our website, trends in the industry, or similar type of information. We do not link aggregate user data with personal information.

Website Privacy

Mortgage Intelligence - Smart Debt Mortgages generally collects and uses personal information from or about its website visitors and users as follows:

Mobile App Data Collection

In the event that you download and/or use any of our applications, we may require and collect, directly from you, information necessary to authenticate you. We may also record your IP geolocation, allowing us to block the access when the user is outside of Canada. When you register on certain apps, you may be required to agree that we may send you notifications regarding your property evaluation, credit score, or general information by electronic messaging on a periodic basis. If you no longer want to receive any notifications, you can unsubscribe at any time.

Quality and Access Rights

Mortgage Intelligence - Smart Debt Mortgages strives to ensure that customers’ personal information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is used. Mortgage Intelligence - Smart Debt Mortgages provides customer access to their personal information. Customers may correct or amend any inaccuracies in their personal information by contacting us using the contract information detailed in the section How to Contact Us of this privacy policy. Mortgage Intelligence - Smart Debt Mortgages has the right to refuse a request for access to personal information if the information is protected by legal privilege, granting access would reveal confidential commercial information, the information was collected for purposes related to the detection and prevention of fraud, the information was generated in the course of a formal dispute resolution process, the information would likely reveal personal information about another individual, the request is vexation or frivolous or any other reason, as authorized under applicable laws.

Personal Information Outside of Canada

In some cases, personal information that we manage may be transferred, processed and stored outside Canada, and therefore may be available to government authorities under lawful orders and laws applicable there.

Security of Personal Information

We will use reasonable security measures to protect your personal information against unauthorized access. Mortgage Intelligence - Smart Debt Mortgages has implemented security measures that contain administrative, technical and physical controls that are designed to safeguard your personal information. No method of transmission over the internet, or method of electronic storage, is 100% secure, however.

Retention

Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received or to satisfy legal requirements.

How to Contact Us

If you have questions, concerns or complaints regarding this Privacy Policy or the personal information that Mortgage Intelligence - Smart Debt Mortgages has about you, or to withdraw consent (when applicable) please contact:

Roselin Tosti
Director, Compliance
Mortgage Intelligence - Smart Debt Mortgages

1410-5140 Yonge Street
North York, Ontario M2N 6L7
By phone: (613) 864-8766
By e-mail: roselin.tosti@invismi.ca

Change of Privacy Policy

Mortgage Intelligence - Smart Debt Mortgages will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. Our privacy policy may therefore change from time to time. We will post any privacy policy changes on our website and, if the changes are material, we will provide a more prominent notice. This privacy policy was last updated on October 2023.

Please note that both the English and French versions of our privacy policy have equal legal value.