PRIVACY POLICY

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This privacy policy (this "Privacy Policy") is provided by GoGreenLightLoans Canada Inc. ("Greenlight", "us", "we", "our", or words of like meaning) and applies to this Site, including any related applications, features, widgets, plug-ins, or online services (this "Site"). This Privacy Policy explains how we collect, record, organize, structure, store, adapt, alter, retrieve, consult, use, share, disclose, disseminate, make available, align, combine, restrict, erase, destroy, or otherwise process ("process") personal information. This Privacy Policy is governed by and forms an integral part of our Terms of Use. Capitalized terms used but not otherwise defined in this Privacy Policy will have the meaning given to them in the Terms of Use. We appreciate the trust that you ("you", "your", "yourself", and words of like meaning) place in us when you choose to access and use this Site and we take that responsibility seriously. We will only process your personal information in accordance with this Privacy Policy unless otherwise required by applicable law. Please read this Privacy Policy carefully so that you understand how we process your personal information. If you do not agree to us processing your personal information or if you do not agree to the terms of this Privacy Policy, you may not provide us with any of your personal information and you should exit and not use this Site or any related services. You may revoke your consent to us processing your personal information at any time by notifying us via email to privacyofficer@gogreenlightloans.com or via the Contact Us page.

Greenlight reserves the right to modify, change, amend, supplement, restate, or replace this Privacy Policy at any time and from time to time. You should review this Privacy Policy from time to time to ensure that you are aware of and accept any such modifications. To obtain a current copy of this Privacy Policy, you may contact us via email to privacyofficer@gogreenlightloans.com or via the Contact Us page.

  1. Personal Information and Privacy Law. In Canada, "personal information" is generally defined as information about a directly or indirectly identified or identifiable individual, subject to more particular definitions or interpretations under Canadian federal and provincial privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) ("Privacy Law"). Privacy Law gives consumers the right to limit the sharing of personal information. Privacy Law requires us to tell you how we process your personal information. This Privacy Policy does not apply to any information that is not personal information as defined under Privacy Law.
  2. Territorial Limitation. This Site is only intended to market and sell to residents of Canada, excluding the Province of Québec (the "Territory"). If you are a resident of a jurisdiction outside the Territory, including Québec or the EU, you are not permitted to access or use this Site in whole or in part and you are not permitted to provide us with any of your personal information. By accessing or using this Site or providing us with any of your personal information, you represent and warrant that you are a resident of the Territory and that you are not a resident of any other jurisdiction, including Québec or the EU.
  3. Minors. Our Website is not intended for anyone under 18 years of age, and especially children under 14 years of age. No one under the age of 14 may provide any personal information to us. We do not knowingly collect personal information from children under the age of 14. If you are under the age of 14, do not access or use this Site or the Services and do not provide us with any personal information, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn that we have collected or received personal information from a child under the age of 14, we will delete that information. If you believe we might have any information from or about a child under the age of 14, please contact us via email to privacyofficer@gogreenlightloans.com or via the Contact Us page.
  4. Your Consent. Greenlight provides this Site, the Content, and the Services to market, advertise, sell, and/or facilitate the provision of Third-Party Products. Greenlight discloses, shares, and transfers your personal information to third parties (each, a "Third Party") in accordance with this Privacy Policy and Privacy Law. We process your personal information with your consent or as permitted or required by Privacy Law. Your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. In most cases, your consent to the processing of your personal information may be implied by the fact that you have provided the information to access or use this Site or the Services or Third-Party Sites or Third-Party Products or related products and services or where processing of personal information is necessary for, or directly relates to, the provision of the Services or Third-Party Products. If we ask for your personal information for a secondary reason (e.g., newsletter subscription or marketing messages), we will ask you directly for your express consent and provide you with an opportunity to withdraw your consent and unsubscribe. If you provide personal information about another person to us, you represent and warrant to us that you have obtained the explicit consent of that individual to enable us to process their personal information as described in this Privacy Policy. If you choose to provide personal information to us, we assume that you consent to the processing of such personal information by us and Third Parties as outlined in this Privacy Policy. By accessing and using this Site or by providing us with personal information for any reason, including to complete a transaction or to verify your payment method, you consent to the processing of your personal information by us and Third Parties, as contemplated under this Privacy Policy.
  5. Revoking Consent. If you do not consent to us or any Third Party processing your personal information, please do not provide your personal information to us. If you change your mind about your consent and wish to revoke your consent, subject to Privacy Law, you may revoke your consent at any time by notifying us of your revoked consent via email to privacyofficer@gogreenlightloans.com or via the Contact Us page. Subject to Privacy Law, we honour and respect all such notices. If you revoke your consent to certain uses of your personal information, Greenlight and/or Third Parties may no longer be able to provide you with the Services or any related products and we may restrict or terminate your access to the Services or any related products in whole or in part.
  6. Collection of Personal Information. We process personal information, including personal information that you provide to us through this Site, the Services, when you interact with us or Third Parties through email, phone, or text messages, when you fill out forms, or through Cookies (as defined below), in accordance with Privacy Law as necessary for us to provide this Site and the Services or to enable Third-Parties to offer and provide Third-Party Products or services and information and generally to fulfill our responsibilities with respect to our business. When you are no longer a user of this Site, we may continue to share your personal information as described in this Privacy Policy and subject to Privacy Law. We collect personal information directly from you or through our interaction with you, including by way of this Site. We may also obtain personal information about you from other sources, including brokers, agents, lenders, lawyers and other professionals, insurers and underwriters, appraisers, credit bureaus, payment processors, fraud detection partners, background (including criminal and financial) checks, and third-party analytics tools. Subject to Privacy Law, the types of personal information we collect from you may include:
    • (a) information you share with us or Third Parties, including when you register as a user on this Site, make a purchase using this Site, or otherwise use this Site or any of our Services, including identifying information such as your name, address, mailing address, postal code, email address, telephone numbers, and other contact details and information, including as may be required to verify your identity and prevent fraud;
    • (b) profile information, including contact information, purchase information, subscription information, Feedback, rating and review information, promotional information, and other information about any user profile you may have on this Site;
    • (c) billing and financial information, including payment method and related information (such as debit or credit card number and related information), bank account information, and billing address;
    • (d) information in connection with your interactions and communications with Greenlight and Third Parties, including purchases of services and refunds, your comments, opinions, and evaluations, your ratings and reviews, your participation in polls or surveys, your messaging to or communications with Greenlight (whether online or offline), disputes you may have with Greenlight or Third Parties, recordings of calls you make to Greenlight customer service agents for training and quality assurance purposes, or when you contact Greenlight with a question or comment or to provide Feedback, and any other information we may collect in the course of providing services to you;
    • (e) demographic information, including age, date of birth, gender, and other similar information about you;
    • (f) preference information, including marketing preferences and service interests, advertising preferences, and your interactions with and responses to online advertisements;
    • (g) technical information about the delivery of emails, SMS, and push notifications from other sources;
    • (h) information we are required to collect pursuant to applicable law or as a consequence of any contractual relationship we have with you, including where failure to collect this information may prevent or delay the fulfillment of our obligations to you and governmental or regulatory authorities;
    • (i) information we collect about you from other sources, including third-party sources and public databases where permitted by applicable law;
    • (j) location information of your device that you use with this Site, if your device settings allow for the collection of location information;
    • (k) device and browsing information including IP addresses, information about your phone, tablet, computer, or device, online browsing activity, unique device identifiers, cookie identifiers, device and browser settings and information, internet service provider (ISP) information, information about when and how you access and use this Site (such as the date and time of your visit or use), and the websites you visit before coming and after leaving this Site; and
    • (l) any other information that Greenlight or Third Parties may collect with your consent or as permitted or required by Privacy Law.
  7. Cookies. We understand that your privacy is important to you and we are committed to being transparent about the technologies we use. We and Third Parties use cookies, web beacons, pixels, clear GIFs, and other similar tracking technologies ("Cookies"), which may be stored on or accessed from your device when you use or visit this Site or any website or app that posts a link to this Site. A Cookie is a small text file that can be stored on and accessed from your device when you visit this Site. It takes up very little room on your system, enables us and Third Parties to collect information about how you use this Site, and helps us estimate the number of persons who use this Site and which areas of this Site are most popular. The use of Cookies enables us to create a more customized experience for you. It allows this Site to recognize your device as distinct from other devices. Login Cookies eliminate the need for you to re-enter your username and password each time you return to this Site. By continuing to access and use this Site (in whole or in part), you agree that Greenlight and Third Parties may use, store, and access Cookies. We use Cookies to, among other things, identify you and your interests, remember your preferences, enhance your user experience, market and advertise to you (including targeted ads), track your use of this Site, facilitate analytics, control access to certain content on this Site, protect this Site, prevent spam and fraud, comply with applicable law, and process requests that you make from us. To administer this Site and for research purposes, we may contract with third parties to track and analyze statistical usage and volume information from the users of this Site. These third parties may use Cookies to help us improve the user experience on this Site, manage associated content, and analyze how users navigate and utilize this Site. We may contract with third parties to send emails to users who have provided us with their contact information. To help measure and improve the effectiveness of such email communications, or to determine whether messages have been opened and links clicked on, such third parties may place Cookies on the devices of these users. You may refuse to accept Cookies by activating or adjusting the appropriate setting of your internet browser to reject the setting of all or some Cookies or alert you when a Cookie is placed on your device. However, if you refuse to accept Cookies or use your browser settings to block all Cookies, you may be unable to access or use this Site or the Services or related functionalities (in whole or part). If you want to remove previously stored Cookies, you can manually delete these Cookies at any time. However, this will not prevent this Site or third parties from placing further Cookies on your device unless you adjust your internet browser setting accordingly. Unless you have adjusted your internet browser setting so that it will refuse Cookies, this Site will issue Cookies when you direct your browser to it. Notwithstanding the foregoing, Greenlight does not process Cookies for profiling, identification, or geolocation purposes, unless you explicitly consent to such processing via the Cookie banner on this Site.
  8. Processing of Personal Information. Greenlight and/or Third Parties may use your personal information for business purposes, including to process transactions, to protect against fraud, to respond to court orders or legal investigations, and for marketing and advertising purposes. Without limiting the generality of the foregoing, the following is a list of some of the ways that Greenlight and/or Third Parties may process your personal information:
    • (a) to process transactions contemplated on this Site, including mortgage origination and facilitating connectivity between you and brokers and lenders as well as other parties, such as professional advisors, insurers and underwriters, and credit bureaus and to provide and improve this Site and the Services, including the Content,
    • (b) to promote and facilitate the sale of Third-Party Products, including mortgages, legal and other professional referrals, appraisal referrals, insurance referrals, and other service and product referrals;
    • (c) to operate and improve our business, provide the Services, process payments, maintain records, conduct research, and determine your satisfaction with the foregoing;
    • (d) to conduct service testing and development, website analytics, and the running and analysis of surveys you choose to take part in to improve this Site or the Services;
    • (e) to process, maintain, administer, and service member lists and profiles;
    • (f) to verify and validate your identity and the information you provide and ensure the security of this Site and the Services;
    • (g) to provide you with material and information regarding the Services and the services of Third Parties, inform you of offers and promotions of Greenlight and Third Parties, and market and advertise to you or facilitate Third Parties to market and advertise to you, including by sending you marketing and advertising communications and customizing the marketing and advertising that Greenlight and Third Parties show you;
    • (h) to communicate with you, including regarding services you request, solicit or respond to Feedback, respond to your requests and enquiries, conduct internal research, and notify you of changes to this Site or any related terms and conditions or policies;
    • (i) to administer billing databases and issue and collect accounts;
    • (j) to personalize your experiences and interactions with this Site, the Services, and Third Parties, including remembering your interests and preferences, customizing service offerings, tracking and categorizing your activity and interests (including by identifying the different devices you use), and enriching your experiences and interactions with this Site and Third Parties;
    • (k) to develop and use knowledge management systems that contain personal information about you;
    • (l) to protect you, Greenlight, and Third Parties against errors and detect and prevent fraudulent activity or misuse of this Site, inappropriate or illegal communications, infringement of intellectual property rights, violation of privacy rights, violations of applicable law, breaches of these Terms of Use, and breaches of any other terms and conditions related to this Site or the Services;
    • (m) to defend or protect you, Greenlight, and Third Parties from harm or in legal proceedings, protect your rights and the rights of Greenlight and Third Parties, protect the security and property of Greenlight and Third Parties, respond to court orders, lawsuits, subpoenas, and government requests, address legal and regulatory compliance, and notify you of service or safety issues;
    • (n) to compile, aggregate, and anonymize information collected by way of this Site or the Services; and
    • (o) to take such actions and do such things and to process personal information as permitted or required by applicable law, including Privacy Law, or for purposes for which you otherwise provide your consent.
  9. Anonymized Data. We may anonymize and/or aggregate your personal information so that it may not be reasonably re-identified in accordance with Privacy Law. YOU ACKNOWLEDGE AND AGREE THAT, SUBJECT ONLY TO PRIVACY LAW, WE MAY USE SUCH ANONYMIZED DATA FOR ANY LEGITIMATE BUSINESS PURPOSE IN OUR SOLE DISCRETION WITHOUT FURTHER NOTICE TO YOU OR YOUR CONSENT.
  10. Sharing and Disclosure of Personal Information. Greenlight may process your personal information and, in particular, may share or disclose your personal information in the following cases:
    • (a) where you provide your consent (express or implied);
    • (b) where you have instructed us to disclose your personal information to a third party for a designated purpose;
    • (c) to Third Parties in connection with our business, including service providers and trading partners, including lenders, brokers, credit bureaus (such as Equifax), professional advisors (such as lawyers), appraisers, insurers and underwriters, providers of other loan products, and electronic signature providers (such as Onespan);
    • (d) to Third Parties to process payments (such as Plaid), collect debts (including for example to a financial institution or collection agent), optimize services, supply online advertising, send newsletters and marketing messages in accordance with applicable Canada's anti-spam laws, send support emails, communicate via messaging services, and analyze information;
    • (e) to Third Parties where we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others, including by exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
    • (f) to our transaction partners and professional advisors in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business;
    • (g) to regulatory or governmental authorities; and/or
    • (h) where we are required or authorized to do so by applicable law or court order.

    Where applicable, we will take steps to require that the recipients of your personal information treat your personal information in accordance with this Privacy Policy and process your personal information only for the purposes for which it was collected or otherwise in accordance with Privacy Law. There are instances where we may process your personal information without your consent, including to comply with a subpoena or court order or to comply with the rules of court regarding the production of records.

  11. Data Security. The security of your personal information is very important to us, and we take the security of your personal information seriously. Consistent with industry standards, we take reasonable steps to help protect the confidentiality and security of personal information you share with us. We have implemented reasonable physical, technological, organizational, and administrative security measures to safeguard personal information in our custody or control, including to protect personal information against unauthorized or accidental processing, modification, loss, and theft, including computer safeguards (such are firewalls and secured files) and physical safeguards. All personal information in our possession or control is processed behind firewalls on secure servers. ALTHOUGH WE TAKE REASONABLE STEPS TO PROTECT YOUR PERSONAL INFORMATION, PLEASE BE AWARE THAT NO SECURITY MEASURES ARE PERFECT OR IMPENETRABLE. WHILE WE STRIVE TO PROTECT YOUR PERSONAL INFORMATION, WE CANNOT GUARANTEE ITS ABSOLUTE SECURITY. HOWEVER, WE COMMIT TO NOTIFYING YOU IN THE EVENT OF A SECURITY BREACH, AS REQUIRED BY APPLICABLE LAW. We encourage you to take steps to help protect the confidentiality and security of your personal information, including the following:
    • (a) if you have a user account on this Site, review your account periodically and promptly report any unexpected activity or unrecognized information;
    • (b) install and maintain the latest security updates and anti-virus software on your computer to help prevent malware and viruses;
    • (c) password-protect your computer and any other devices you use to connect with this Site;
    • (d) use strong and complex passwords and, where possible, two factor authentication with your use account and your devices, not use the same password on more than one website, and not share your passwords with others; and
    • (e) sign out or log off of website sessions so that your session is closed, especially when using a public computer or shared device.
  12. Links and Third-Party Websites. For your convenience, this Site offer links from and to Third-Party Sites. When you click on such links, they will direct you away from this Site. Once you leave this Site or are redirected to a Third-Party Site, your personal information is no longer governed by this Privacy Policy. You should read the privacy policies of Third Parties before providing any personal information on any Third-Party Site linked to this Site. YOU ACKNOWLEDGE AND AGREE THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, GREENLIGHT WILL NOT BE RESPONSIBLE FOR, AND EXPRESSLY DISCLAIMS ANY AND ALL LIABILITY FOR, THE PROCESSING OF PERSONAL INFORMATION BY THIRD-PARTIES THAT YOU CONNECT WITH VIA LINKS FROM THIS SITE.
  13. Third-Party Service Providers. Greenlight or this Site may transfer your personal information to third parties who are our service providers, including to administer or provide services or information to you. We use reasonable measures to require such third parties to process your personal information for the purposes to which you consented. Such third parties may include IT services providers, payment processors, debt collection agencies, service optimization providers, advertising networks, newsletter and marketing communication providers, customer support services, messaging service providers, data analytics firms, fraud prevention organizations, and credit risk reduction services. Additionally, we may share your personal information with transaction partners, professional advisors in the context of corporate transactions (such as mergers, acquisitions, or asset sales), regulatory or governmental authorities as required by law, and other parties where necessary to protect the rights, property, or safety of Greenlight, our customers, or others. Each of these third parties has its own privacy policies governing the personal information we provide to them, including for purchase-related transactions or for marketing purposes. We recommend that you read the privacy policies of such third parties carefully so you understand the manner in which your personal information is processed by them.
  14. International Data Transfer. Personal information may be transferred to or otherwise processed outside Canada to a foreign country that may or may not provide the same level of protection for personal information as Canada and may be available to the government of those countries under applicable legislation or court order in those countries. As a result, your personal information may be processed outside Canada, including in connection with the purposes described in this Privacy Policy. If you elect to proceed with a transaction that involves a third party, your personal information may become subject to the laws of the jurisdiction in which that third party or its facilities are located, and contractual or other measures we may use to protect your personal information will be subject to the legal requirements of the foreign jurisdiction where your personal information may be processed, including lawful requirements to disclose information to government authorities in those countries. For example, if your personal information is shared with a third party located in the United States, your personal information may be subject to disclosure under United States legislation, including the Patriot Act.
  15. Your Rights. Your principal rights under Privacy law include the right to access, the right to rectification, the right to erasure, the right to object to processing, the right to data portability, the right to complain to a supervisory authority; and the right to withdraw consent. You have the right to confirmation as to whether or not we process your personal information and, where we do, access to the personal information, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal information concerned and the recipients of the personal information. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal information. The first copy will be provided at cost, but additional copies may be subject to a reasonable fee. In some circumstances you have the right to the deletion of your personal information without undue delay, including where the personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed, where you withdraw consent to consent-based processing, where you object to the processing under certain rules of applicable privacy and data protection law, where the processing is for direct marketing purposes, and where the personal information has been unlawfully processed. However, there are exclusions of the right to deletion, including where processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, or for the establishment, exercise, or defense of legal claims.
  16. Accessing and Correcting your Information. It is important that your personal information that Greenlight processes is accurate and current. Please keep us informed if your personal information changes. If you want to review, verify, correct, or withdraw consent to the use of your personal information, you may contact us via email to privacyofficer@gogreenlightloans.com or via the Contact Us page to request access to, correct, or delete any personal information that you have provided to us. If we are required to delete your personal information, we may also need to delete your membership on this Site. We may not accommodate a request to change information if we believe the change would violate any applicable law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, and if so, we will notify you of any fee in advance. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices or appliable law. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation, including information protected by solicitor-client privilege, information that is part of a formal dispute resolution process, information about another individual that would reveal their personal information or confidential commercial information, and information that is prohibitively expensive to provide.
  17. Retention and Destruction. We will retain and destroy your personal information in accordance with applicable law, including law applicable to the financial services industry. In some cases, this may require us to retain your personal information for up to seven years. In principle, we retain your personal information only to fulfill the purposes specified in this privacy Policy and/or for the purposes for which you have provided your consent. However, there are certain exceptions. After the retention period, we will securely dispose of your personal information. Should you want more information about our retention period and destruction process, please contact our Privacy Officer.
  18. Contact Us. If you have any questions or concerns about this Privacy Policy or if you wish to revoke your consent to us processing your personal information, you may contact our Privacy Officer at any time via email to privacyofficer@gogreenlightloans.com or via the Contact Us page.

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