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Privacy Policy

At Argentum Mortgage and Finance Corp (herein after referred to as “ARGENTUM”), we are
committed to protecting the privacy and confidentiality of the personal information of our
clients (individually, the “Client” and collectively, the “Clients”.) As financial service
providers, we have a professional obligation to maintain in confidence information we
receive within our role as a financial services provider. The purpose of this Privacy
Policy is to advise clients as to why we ask for personal information, how we use it,
what safeguards we employ, and how to contact us with privacy-related matters.

What Is Personal Information?

In this Privacy Policy, “Personal Information” means information that is gathered in connection
with an application, pre-approval, request for information for a mortgage(s) or loan(s) and
insurance or other product through ARGENTUM or ARGENTUM affiliates and is provided to, or
collected by, ARGENTUM and its staff or by ARGENTUM’s agents, associates, and affiliates on
ARGENTUM’s behalf (collectively, “ARGENTUM”).

Why ARGENTUM Collects Personal Information

ARGENTUM collects and uses Personal Information for the following purposes:

  • Provide mortgage brokering services to the Client and offer products and
    services best suited to their needs, including arranging and/or renewing
    loan(s)/mortgage(s), informing the client of group creditor insurance and other
    products offered or approved by ARGENTUM or its affiliates that may be of interest to
    the Client;
  • Checking Client credit worthiness through credit bureau inquiry and personal
    information agents who have information on a Client’s financial position.
  • Advising Clients of the financial options, as well as, ongoing developments of the
    mortgage market and industry;
  • Auditing the services provided to our Clients;
  • Compliance with all municipal, provincial, federal and other applicable laws; and
  • Such other specific purposes which are communicated to the Client by a member
    of ARGENTUM before collection of such Personal Information.

Except when otherwise permitted by law, we will only use a Client’s Personal
Information for the purposes identified to the Client. When Personal Information is to be
used for a purpose not identified, we will take all reasonable steps to ensure that new
purpose is identified prior to use.

How Do We Collect Personal Information?

The Client is our main source of information. With the Client’s consent, we may also
obtain information directly from a third party to help us determine eligibility for various
financial products and services. For credit matters, for example, it is essential that we know the clients’ financial worth as well as the clients’ credit record. We will also contact
other lenders, financial institutions, credit bureaus and employers. Consent is therefore
important because without it, we will not be able to carry out the appropriate inquiries
and it might be difficult for us to offer the credit product requested. In most cases,
consent is given on the forms used for specific products or, from time to time, on a
separate form. The declaration of consent is clear and unambiguous.

Consent

A clients’ provision of Personal Information to ARGENTUM means that they agree and consent
that ARGENTUM can collect, use and disclose such Personal Information in compliance with
this Privacy Policy. ARGENTUM will not collect, use or disclose a Client’s Personal Information
without the Client’s requisite consent, except in certain extraordinary circumstances.
Such extraordinary circumstances shall include without limitation, when legal, medical
or security reasons make it impossible or impractical to obtain consent or where it is
otherwise in the best interests of the Client.

The most common method we use to obtain a Client’s consent is by way of the Client’s
consent as confirmed by the application or Client Agreement. Where practicable, we may
also obtain a Client’s consent through oral communications or other written documentation.

Our Clients may withdraw their consent by written notice to us at any time, subject to
any legal or contractual restrictions and reasonable notice. A Client’s refusal to provide,
or subsequent withdrawal of, his or her consent may affect ARGENTUM’s ability to provide the
Client with mortgage services. A member of ARGENTUM will inform the Client of the
implications of such withdrawal. To withdraw consent, a Client should contact the Chief
Privacy Officer in writing at:

Attn: Chief Privacy Officer
Argentum Mortgage and Finance Corp
14993 Yonge Street Suite 201
Aurora, Ontario,
L4G 1M5
289-466-5197

Use and Disclosure of Personal Information

We will use a Client’s Personal Information to provide financial advice and services to
the Client, to administer our database, to include Clients in direct marketing Activities
and for the other uses described above under the heading “Why ARGENTUM Collects Personal
Information”. Under certain circumstances, ARGENTUM will disclose a Client’s personal
information to third parties. Specifically, Personal Information may be used, shared and
disclosed to, from, or with, the members of ARGENTUM, witnesses in a litigation proceeding,
experts retained on a Client’s behalf, private investigators, agents retained on behalf of
a Client, credit reporting agencies, credit bureaus, as well as such other third parties as
are necessary to facilitate the matter for which the Client has retained our office and
provided its consent.

Under certain circumstances ARGENTUM may disclose Personal Information where:

  • required or authorized by law to do so, for example if a court issues a subpoena;
  • a Client has consented to the disclosure;
  • when mortgage services by ARGENTUM are provided to a Client requiring us to give
    Personal Information about a Client to a third party (for example, to a lender in a
    real estate mortgage transaction) the Client’s consent will be implied, unless the
    Client tells us otherwise;
  • where it is necessary to pull a credit bureau for purposes of processing a
    mortgage transaction;
  • if ARGENTUM engages a third party to provide administrative or support services to us
    (such as computer back-up services, shredding or archival file storage) and the
    third party is bound by our Privacy Policy;
  • protection of ARGENTUM’s best interests;
  • protection of public interests such as the denouncement of criminal Activity such
    as fraud or money laundering. In all such cases, authorities are contacted and
    personal information may be disclosed;
  • if we retain a law firm(s) to Act on our behalf for any reason; or
  • if the information is already publicly known.

Limiting collection and retention of Personal Information

ARGENTUM limits the collection of a Client’s Personal Information to that which is necessary
for the purposes identified in this Privacy Policy as same may be amended from time to
time, or for any additional purpose identified to the Client before the collection of the
Personal Information. As well, Personal Information is not used or disclosed for
purposes other than those for which it was originally collected, except with the consent
of the Client or as otherwise permitted by law.

ARGENTUM will retain Personal Information only for so long as it is needed to fulfill the
purposes for which it was obtained and to meet our professional requirements as set
out our governing regulatory bodies and/or any other legal requirement, statutory or
otherwise, from time to time.

Accuracy

ARGENTUM strives to ensure that a Client’s Personal Information is as accurate, complete, and
up-to-date as is necessary for the purposes for which it is used.

Safeguards

ARGENTUM endeavours to maintain adequate safeguards to protect against loss, theft,
unauthorized access, disclosure, copying, use or modification of Clients’ Personal
Information in the care of ARGENTUM. ARGENTUM uses various methods to safeguard personal
information, including physical security, computer and electronic security, destruction of
information no longer needed, and contractual protections with third party data
processors.

Protection

Client lists are never passed on to third parties other than affiliated members of ARGENTUM.
When they are hired, our employees and agents must undertake to respect the
confidential nature of client information. Only employees and associates who need to
view the file as part of their work have access to this information.

Accountability, Openness and Client Access

ARGENTUM is responsible for the Personal Information under its control and has appointed a
Chief Privacy Officer to oversee our efforts to comply in all material respects with
applicable privacy legislation and the terms of this Privacy Policy. The Chief Privacy
Officer and those designated by the Chief Privacy Officer address and investigate
questions or concerns regarding a Client’s Personal Information.

ARGENTUM will provide a Client access to their Personal Information. The Client may correct
or amend any inaccuracies in the Client’s Personal Information. ARGENTUM 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;
  • To protect our firm’s rights and property.

Changes to Privacy Policy

ARGENTUM will from time to time review and revisit privacy practices and this Privacy Policy.

ARGENTUM Web site

Our Web site may contain links to other sites, which are not governed by this Privacy
Policy. On our Web site, like most other commercial Web sites, we may monitor traffic
patterns, site usage and related site information in order to optimize our web service.
We may provide aggregated information to third parties, but these statistics do not
include any identifiable personal information.

Communicating With ARGENTUM

We recognize that convenience and quick access to advice must be balanced with
security needs. We use many different means to communicate with clients, some of
which are more convenient such as e-mail. Our emails are sent with industry standard
128 bit encryption. Such encryption however does not guarantee privacy and security
as encrypted messages can nonetheless be subject to interception and translation. If
clients do not wish us to communicate by e-mail, they may speak with the
consultant/broker/agent handling the matter about alternative arrangements.

Attn: Chief Privacy Officer
Argentum Mortgage and Finance Corp
14993 Yonge Street Suite 201
Aurora, Ontario,
L4G 1M5
289-466-5197

Agent Protection of Data

All agents and brokers will take reasonable steps to protect personal data supplied by
clients.

All original documentation will be kept in secure premises not accessible to the public.
Once a file is complete, any un-required documentation will be returned to the client
immediately.

Original documentation will be submitted to head office in either hardcopy or electronic
format prior to the closing of the transaction. While agents may retain copies of files,
every effort must be made to safeguard the information on hand.
It should be noted that all files are the property of ARGENTUM. Although brokers and
agents may retain data for marketing purposes, ARGENTUM is ultimately responsible
for all clients.

Any documentation not further required, must be shredded immediately.

All electronic documentation must be password protected. Laptops containing client
files shall not be left unattended in public areas.

Head Office Protection of Data

Head Office will take reasonable steps to ensure the security of the data of client files.
Scanned documentation must be adequately protected and catalogued. All clients
records and personnel records will be kept in locked cabinets or in secured electronic
format. All computers at head office will be password protected and data will be backed
up on a regular basis by a third-party source.

Advertising

All advertising will be in compliance with the standards of practice, as outlined in the
Mortgage Brokerages Lenders and Administrators Act.

All advertising must be approved by the principal broker or designate before final orders
are placed. This includes the ordering of business cards, printed material, websites,
media advertising, flyers, brochures, and all other marketing materials.

The principal broker will approve the draft ad, and must also approve the final artwork or
content before the order is finalized.

Complaints

The principal broker (or designate) shall Act as the Chief Complaints Officer for the company.

Upon receipt of a complaint from a consumer or an investor, the Complaints Officer (or
designate) will take immediate action to investigate.

Should the complaint relate to a completed file, the Complaints Officer will pull existing
documentation on file with the company. The Complaints Officer will review the
documentation, and then forward the complaint to the specific agent or broker for
comment.

Should the complaint relate to a file in progress, the Complaints Officer will immediately
contact the agent or broker responsible for the file and forward the complaint for
comment.

The Complaints Officer will respond to all complaints verbally within 48 hours of receipt
and will follow up with a written response as quickly as possible.

Should the agent or broker responsible for the file not be forthcoming in dealing with the
matter, the Complaints Officer will take all reasonable steps to deal with the matter.

Should the complaint relate to an issue relating to the Mortgage Brokerage Lenders and
Administrators Act, all efforts will be made to determine if the transaction was in
compliance with the legislation. If a breach of the legislation is discovered, remedial
Action will be taken immediately.

Should the complaint relate to a potential claim against the firm’s errors and omissions
insurance policy, the Complaints Officer will notify the insurer of the potential claim as
soon as possible.

At no time will an agent or broker respond directly to the complaint. All
responses will come directly from the Complaints Officer.