Privacy Policy


May 3, 2023

Collecting and using personal information is necessary to our business as a
financial services provider.  Protecting your personal information and
respecting your privacy is very important to us. We want to tell you how and
why we collect, use and disclose the personal information you provide to us
when you open and maintain or purchase securities through an account with

This Privacy Policy has been developed in compliance with the Personal
Information Protection Act(“PIPA”), the Personal Information Protection and
Electronic Documents Act (“PIPEDA”).

Your consent

By engaging us to provide mortgage or investment management services to you
or submitting information to us in connection with our services, you are
indicating your consent to our collection, use and disclosure of your
personal information in the manner described below.  Your consent may be
giving in writing, verbally, electronically, or through our authorized
representative(s), such as your mortgage agent or our Exempt Market Dealer.
Consent can also be implied or inferred from certain actions.  For example,
if you present your driver’s license as identification to your mortgage
agent, it is understood that you are giving your consent to provide us with
your driver’s license reference number and photo identification to be kept
in our files.  Or when you approach us to obtain information, inquire about
or invest in our fund. 

Our collection of your personal information

In order to provide our services to you, we will ask you to provide certain
personal information, such as your personal contact information, employment
information, financial and banking information, investment statements, tax
returns, debt statements, information about properties you may own, copies
of wills, powers of attorney, insurance policies, employment benefits,
retirement benefits, legal documents and information regarding your
investment knowledge, objectives, strategies, needs and values as well as
when assessing prospective borrowers in reviewing and approving a mortgage
application file.   We request this information to provide our services to
you, and to comply with the Mortgage Brokerages, Lenders and Administrators
Act, 2006 (Ontario) (“MBLAA”), applicable securities and other laws.

We collect personal information from completed applications and forms, your
interaction with us, your CapGap representative, third parties we work with
to issue and manage our offering, whether now or in the future; public
sources, such as government agencies and websites.  We may collect your
personal information through public sources including other banks or
financial institutions, your employer, credit reporting agencies. 

All data that we receive is obtained directly or indirectly from you when
you choose to use our Service. This includes the following situations:

a.      When you register on our systems and portal;
b.      When you subscribe to our newsletter(s) or mailing lists;
c.      When you schedule time with one of our team members;
d.      When you share content from our website and portal; or
e.      When you interact with us through email, via social media platforms,
or by other means not outlined here.

Our use of your personal information

We may use your personal information to maintain our relationship with you,
including communicating with you by email, text, message, telephone and fax,
to respond to your communications, to provide services to you, market
services and investments to you, to verify your identity and confirm the
accuracy of your information, to evaluate mortgage applications and
administer our fund, comply with legal requirements such as regulatory
filing, protect against fraud, and as otherwise required or authorized by

Our disclosure of your personal information

We may disclose your personal information in the following limited

(a) Disclosure to partners, authorized agents, service providers and
employees or representatives who need the information to complete their
duties for us.  We may provide your personally identifiable information to
our agents, service providers, or organization or person you give consent
to, such as the financial institution that holds your investment assets in
custody, or a partner that provides a dashboard of your investment, or other
institutions that may have granted you credit, credit bureaus with respect
to your credit or financial history, but only where it is reasonably
necessary to do so in connection with the provision of our services or,
where possible, consent has been obtained from you.

(b) Disclosure required or authorized by law, etc. – We may disclose your
personal information (i) to a government institution that has asserted its
lawful authority to obtain the information, (ii) where we have reasonable
grounds to believe the information could be useful in the investigation of
unlawful activity, (iii) to comply with a subpoena or warrant or an order
made by a court, person or body with jurisdiction to compel the production
of information, (iv) to comply with court rules regarding the production of
records and information, (v) to our legal counsel, or (vi) as otherwise
required or authorized by law.

We keep your information for one of the following time periods, whichever
is longer:

1.      As long as we are required by law and guidelines set for the
financial services industry
2.      As long as we need to for managing the products and services we
provide you

When personal information isn’t needed anymore, it is destroyed, erased, or
can be made anonymous.

Location of your personal information

We store and process your personal information in Ontario, Canada. However,
the disclosure of your information in accordance with this policy and
applicable law may result in your personal information being transferred
outside of Canada, including to the United States. We use cloud-service
providers which can and do store data outside of Canada. The laws of other
countries regarding the collection, use, and disclosure of personal
information may be different from the laws of Canada.


Any personal information we collect, use, or disclose should be as correct,
complete, and up-to-date as possible for the reasons it is used.  If your
contact information changes, please contact us right away. 

We make all reasonable efforts to make sure that the personal information
we collect and keep in your file is as correct, complete, and up-to-date as
it needs to be for the identified purposes. 

We rely on you to give us accurate information and to let us know about any
changes, such as changes to your contact information or when your driver’s
license expires. 

Access to your personal information

You may request access to your personal information and information about
our privacy practices by contacting us at the address indicated below.
Subject to certain limited exceptions prescribed by law, you will be given
reasonable access to your personal information within a reasonable time, and
will be entitled to challenge the accuracy and completeness of the
information and to have it amended as appropriate.


We take the security of your personal information very seriously and take
reasonable organizational, technological and physical measures to protect
your personal information against unauthorized access, collection, use,
disclosure, copying, modification or disposal, or similar risks.

How to contact us

If you wish to obtain further information about our privacy practices or to
address any matter concerning this policy, please send a written request to
the attention of the Compliance Officer at [email protected]