CMLS Financial’s Commitment to Privacy

CMLS Financial is committed to protecting your privacy and the confidentiality of your personal information and has developed this policy to ensure these goals. The collection and use of personal information is fundamental to our business of providing financial products and services for our customers. That includes treating your personal information fairly and with care.

What is Personal Information?

Personal Information is information that is specific to you and includes your name, address, age and other identifiers such as your SIN, income, assets and liabilities, as well as your financial and employment records. Personal information may also include whether or not credit is extended, the way in which you use our products and services and to whom information is disclosed.

Accountability to Customers

At CMLS Financial, we take our commitment to securing your privacy very seriously. We have appointed a member of our management team as CMLS Financial’s Privacy Officer. The Privacy Officer is responsible for analyzing all personal information handling practices at CMLS Financial and insuring that our Privacy Policy is up to date and in force at all times. Our employees and representatives are informed about the importance of privacy and receive information periodically to update them about our Privacy Policy and related policies. Each employee and representative of CMLS Financial is responsible for the personal information under his or her control.

Why Do We Collect Your Personal Information

There are a number of reasons why we collect and use personal information. Either before or at the time we collect personal information, we will explain how we intend to use it and limit collection and use to those purposes. We will ask for your further consent before it can be used for any other purpose. We obtain most of the information about you directly from you. Additional information may be obtained via credit reporting agencies and other third party sources.

Personal information is collected to establish a relationship and to serve your financial needs. It is used

• to verify your identity;

• to determine the suitability of our products and services;

• to evaluate your application for financing, particularly with respect to credit risk;

• to understand your financial needs and determine which financial products or related services may be of use to you and help meet your needs, and to offer those to you either ourselves or organizations with which we have strategic alliances;

• to share with third parties CMLS Financial may select and make arrangements with as its business associates for mortgage, credit and other insurance, for card services and for homeownership related products and services; those business associates may directly or through us determine eligibility for products and offer them to you;

• to administer our financial and lending programs and provide ongoing service including dealing with your mortgage agent or broker; and

• to comply with legal requirements and regulations

Consent

Your consent is required before we may collect, use or disclose your personal information, except in special circumstances, such as during a fraud investigation and in other legal and security situations.

We accept any of the following as your consent for CMLS Financial’s existing and future collection, use and disclosure of your personal information for the purposes identified in this policy or in any document in which you expressly give your consent:

• your unrestricted provision of information directly to CMLS Financial or through licensed agents or mortgage brokers;

• your consent as obtained through an application process, or in a mortgage commitment, mortgage or related document;

• your receipt of this Privacy Policy, unless you advise us, either orally or in writing, that you do not agree with the terms stated in this Policy, and that you wish to opt out of all or portions of it.

Your consent can be expressed to us orally (such as over the telephone), in writing (such as on an application) or electronically (such as via the internet). Providing your SIN for credit products is optional. If you provide it, we will use it to keep your information separate from others with a similar name, including in our collection and disclosure of information with credit reporting agencies.

You may withdraw your consent at any time upon reasonable notice, subject to legal or contractual restrictions: for example, you may not withdraw your consent to disclosure of your information to our service providers (as defined below) during the term of your mortgage. Please note that withdrawing your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive.

To withdraw your consent, you should contact our Privacy Officer at the address or telephone number listed below.

Limiting Collection, Use, Disclosure and Retention of Information

The personal information about you which we collect will be limited to that which is necessary for the purposes we identified to you. Information will be collected by us only by fair and lawful means.

We will not use or disclose your personal information for purposes other than those identified to you at the time or before your consent was given. We will seek your further consent before using the information for purposes beyond the scope of your original consent.

There are some necessary types of disclosure of your personal information which occasionally occur as part of CMLS Financial fulfilling its routine obligations and conducting its business in the ordinary course. This includes, for example, disclosure to third party lenders, rating agencies, consumer reporting agencies, partners, consultants and suppliers to CMLS Financial (also known collectively as "service providers").

We will retain your information only for the time it is required for the identified purposes and for a reasonable length of time thereafter in case we need to meet any potential obligations or legal or government requirements. Once your personal information is no longer required, it will be destroyed or made anonymous.

Keeping Your Information Accurate

CMLS Financial strives to base its decisions on each customer’s accurate, complete and relevant personal information. We rely on you to disclose all material information and to inform us of any changes so we may update our files.

Safeguarding Your Information

We will protect your information, whether in electronic or paper based format, with strict safeguards and security measures, to protect it from unauthorized access, disclosure or misuse. We review our security procedures regularly to ensure that they are being properly administered and that they remain effective and appropriate.

Providing Access to Your Information

We will give you access to the information we retain about you when you request it and satisfactorily identify yourself. We will tell you what personal information we have, what it is being used for, from whom it was collected and to whom it has been disclosed (except where such disclosure was to a governmental body or service provider for routine purposes or to a governmental body where that body has exercised a legal right to obtain the information).

We will do so within a reasonable time and a nominal fee for processing your request may apply.

We may not provide access to personal information within our possession or control if it:

• contains references to other individuals

• doing so may reasonably be expected to threaten the security of another individual;

• would reveal confidential commercial or proprietary information;

• is subject to solicitor-client or litigation privilege;

• is used for detection and prevention of criminal activity and dealings in proceeds of crime; or

• cannot be disclosed for any other legal reasons

If we deny your request for access to your personal information, we will advise you in writing of the reason for the refusal.

Respecting and Responding to your Privacy Concerns

CMLS Financial has prepared this plain language Privacy Policy to keep you informed. It is made available to the public in paper form at the address set out below, and in electronic form at www.cmls.ca. Updated versions of this Privacy Policy may be posted on CMLS Financial’s website at www.cmls.ca.

If you have any questions or concerns regarding your privacy or this Privacy Policy, you should direct them to CMLS Financial’s Privacy Officer at the telephone, e-mail address or mailing address below.

CMLS Financial Privacy Officer

Address: 18 York Street, Suite 1500, Toronto, ON M5J 2T8

Telephone No: 877.750.2657
Confidential Fax No: 888.503.5639
E-mail address: privacy@cmls.ca

Please be sure to include your name, address, preferred method of communication, the nature of your complaint and relevant details, including your past communications with us. If you have a complaint and it is justified, we will take the steps necessary to resolve the issue, including, if necessary, amending our Privacy Policy and procedures.