The purpose of this Privacy Policy is to advise clients ("Client" and collectively, the "Clients") as to why we, THINK Financial (hereinafter referred to as "THINK"), ask for personal information, how we use it, what safeguards we employ, and how to contact us with privacy-related matters. Our privacy policy is posted here on our website for client access.

What is Personal Information?

In this Privacy Policy, "Personal Information" means information that is gathered in connection with an application, funding, servicing, or requests for information about these services or other products THINK provides or is collected by THINK and its staff or by THINK's employees, associates, and affiliates on THINK's behalf.

Why THINK collects Personal Information

THINK collects and uses Personal Information for the following purposes: 

• Provide mortgage products 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 THINK or its affiliates that may be of interest to the Client;
• Checking Client creditworthiness through credit bureau inquiry, with employers who have information on a Client's financial position, and with the Canada Revenue Agency (CRA) to verify Notices of Assessment submitted.
• 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 THINK before the collection of 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 the 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 Client's financial worth as well as the Client's 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 Client's provision of Personal Information to THINK means that they agree and consent that THINK can collect, use and disclose such Personal Information in compliance with this Privacy Policy. THINK 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. Where practicable, we may also obtain a Client's consent through oral communications or other written documentation.

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 mortgages and mortgage pools, to include Clients in direct marketing activities and for the other uses described above under the heading "Why THINK Collects Personal Information." Under certain circumstances, THINK 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 THINK, witnesses in a litigation proceeding, experts retained on a Client's behalf, private investigators, employees 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, THINK 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 THINK are provided to a Client requiring us to give Personal Information about a Client to a third party, 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 THINK 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 THINK'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

THINK limits the collection of a Client's Personal Information to that which is necessary for the purposes identified in this Privacy Policy, and 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. THINK 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 by our governing regulatory bodies and/or any other legal requirement, statutory or otherwise, from time to time.

Accuracy

THINK 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

THINK 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 THINK. THINK 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 THINK. When they are hired, our employees 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

THINK 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 or those designated by the Chief Privacy Officer to address and investigate questions or concerns regarding a Client's privacy can be reached at:

Attn: Chief Privacy Officer
THINK Financial
3600, 205-5 Ave SW
Calgary, AB  T2P 2V7
Phone: 587-352-8515

Changes to Privacy Policy

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