We do collect from time to time a wide range of personal information about identifiable individuals for the purpose of providing services to our Clients. When we collect personal information from you, our Client, every member of our company has the ability to access that personal information both physically and electronically. We have spent an inordinate amount of time selecting and training the members of our company to ensure that they understand and respect the very private and discrete nature of our work. Every member of our company has been carefully briefed on the fact that no personal information about our Clients can be disclosed to any third party without your prior consent.
Your personal information is kept under lock and key with restricted access to the floor on which our offices are located in off-hour times. If your personal information is kept electronically, it is password protected with only those who “need to know” having access to such password.
Our computer technology consultants do have access to all electronically held documents and has signed a confidentiality agreement that prevent them from disclosing any personal or other information to any other person without our prior written consent which we will not provide without your prior consent.
As a private mortgage lender and in respect of the administration of the loan portfolios, we do collect personal information about our Clients. When providing our services, we will often interact with; lawyers hired to place the mortgages and collect the indebtedness on a loan; the Client; and his or her advisors including any financial and legal advisors and in those interactions, personal information collected and used by this company will be disclosed and exchanged between the company and those advisors and may also be shared with securities regulators upon request by the regulators. We confirm our understanding that you will take the necessary steps to ensure that the privacy policies of such other advisors is acceptable to you and we confirm that you have waived the necessity for us to enter into a specific written agreement with such other advisors in order to ensure that their privacy policy is similar to ours or is otherwise satisfactory to you.
We do collect from time to time a wide range of personal information about identifiable individuals for the purpose of providing services to our Borrower. When we collect personal information from you, the Borrower, every member of our company has the ability to access that personal information both physically and electronically. Every member of our company has been carefully briefed on the fact that no personal information about our Borrowers can be disclosed to any third party without your prior consent.
Your personal information is kept under lock and key with restricted access to the floor on which our offices are located in off-hour times. If your personal information is kept electronically, it is password protected with only those who “need to know” having access to such password.
Our computer consultants do have access to all electronically held documents and has signed a confidentiality agreement that prevent them from disclosing any personal or other information to any other person without our prior written consent which we will not provide without your prior consent.
As a private mortgage lender, we often find ourselves working alongside other credit agencies, investors, potential investors, legal advisors and the Borrowers’ advisors including but not limited to financial planners, legal advisors and accounting advisors. When carrying out our business our client’s personal information is regularly exchanged among this company and those additional advisors for the purposes of securing your credit history, assessing the value of the collateral being tendered, substantiating representations made to us, obtaining personal references and the like. We confirm that when you apply to our company for credit, you are implicitly instructing and consenting to our collection, use and disclosure of your personal information for the purpose of allowing us to be engaged in the activities and to provide the services in respect of seeking financing for you. We confirm our understanding that you will take the necessary steps to ensure that the privacy policies of such other advisors is acceptable to you and we confirm that you have waived the necessity for us to enter into a specific written agreement with such other advisors in order to ensure that their privacy policy is similar to ours or is otherwise satisfactory to you.
Various laws require that we retain our files for minimum periods of time. We will keep your files for at least those minimum periods prescribed by law. Your closed file will be kept either on site or in off-site storage where disclosure of its contents is limited to our company alone. When we destroy your file, we will undertake such destruction in a manner that will eliminate or at least minimize the risk of any personal information being disclosed to any unauthorized third party .
You can review your personal information on reasonable notice, during regular business hours by making that request of the Privacy Policy Coordinator. You have the right to request a correction be made to your personal information. The partners of the company will determine whether that correction should be made or how it should be dealt with within 45 days of the request for correction having been first made to the Privacy Policy Coordinator.
You can make an inquiry or complaint about anything having to do with this privacy policy directly to the Privacy Policy Coordinator at any time, in writing. Our Privacy Policy Coordinator, Milly Bergenstrom can be contacted at (780) 702–9240 or by mail at Suite 1000, 8215 112 Street, Edmonton, Alberta T6G 2C8 Fax (780) 439–9472 or by email at milly@caplink.ca.
As of January 2004, you are able to make a request under the Personal Information Protection Act (PIPA)to an organization for access to your own personal information. You may also request a correction to your own personal information. The organization must respond to your request within 45 days.
If you are not satisfied with the response you receive, you may request a review of the organization’s decision by the Information and Privacy Commissioner. The Commissioner may instruct an individual to discuss the decision with the organization prior to accepting the initial request for review. If a resolution cannot be reached between the parties, the Commissioner may decide to authorize a review into the matter.
For a copy of PIPEDA, please access the Privacy Commissioner of Canada website at: www.privcom.gc.ca
For a copy of PIPA, please access the Information Management, Access and Privacy website: www.psp.gov.ab.ca
Our privacy policy may change from time to time and those changes will be recorded in this document and be published on our website.
caplink.ca (the “Website”) is a website owned by Caplink, with a registered address of Suite 1000, College Plaza 8215 112 Street Edmonton, Alberta Canada T6G 2C8(the “We”, “Us” or “our”).
We want you to understand how we use the information that you provide to us. This Privacy Policy sets out how we obtain and use the “Personal Information” which you provide us. Personal Information may include your name, address, telephone number, email address, date of birth, and other data which may directly or indirectly identify you.
As the legal environment, technology, and operations change, it may become necessary for us to make changes to this Privacy Policy and all such changes will be posted on the Website.
We may gather Personal Information through the Website in several different ways:
We also gather other information (“Other Information”), which cannot identify you unless it is used in conjunction with actual Personal Information. For example, we may collect your computer’s Internet Protocol address (i.e. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We may receive and store certain information whenever you visit the Website. We may use your IP address to help diagnose problems with our server and to administer the Website, and to help identify you. Your IP address may also be used to gather broad demographic information, and for other purposes. Such Other Information cannot generally be used by us to identify you, and as such is not considered Personal Information.
We reserve the right to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the Website and to inform advertisers of such information as well as the number of users that have been exposed to or clicked on their advertising banners.
We may use the collected Personal Information for various purposes including:
We may employ third party companies and individuals to facilitate our Website and business (“Service Providers”), to provide services on our behalf, to perform services or to assist us in analyzing how our Website is used. We also may employ agents to fulfill functions on our behalf, such as providing marketing assistance, analyzing data, preparing and maintaining site content, processing credit card payments and providing customer service. These agents have access to user and customer information as required in order to help them perform their functions on our behalf, but they are not allowed to use that information for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Website, such as Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of the Website This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
We may use third-party Service Providers to show advertisements to you to help support and maintain our Service, such as Google, who as a third party vendor, uses cookies to serve ads on our Website. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Website or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
We may use remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors may use cookies to inform, optimize and serve ads based on your past visits to our Service. Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
We may use Facebook’s remarketing service which is provided by Facebook Inc.
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/; the Digital Advertising Alliance of Canada in Canada: http://youradchoices.ca/; or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/; or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
One of our Service Providers is Adster, which employs a tool on our behalf, called SuperDASH™, which is used for ROI tracking, lead aggregation, and marketing transparency. The tool is currently hosted on a dedicated server belonging to Adster wherein a MySQL database stores form submission data collected from our Website. Personal Information collected by Adster on our behalf using SuperDASH™ may include your name, email, address, phone number, and other Personal Information which you may provide to us. The Personal Data collected by Adster may only be used by us and not by Adster, except in the course of providing us with certain services for which we have contracted Adster for in connection with our business and in compliance with this Privacy Policy. Adster will retain and/or destroy and/or produce and/or deal with all such collected Personal Information in accordance with our Privacy Policy, on our behalf.
Persons under the age of majority in their jurisdiction must ask their parents or legal guardians for permission before sending any information about themselves to us, or via the Website or to Website payment processors.
We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send. If you do not wish to receive notification of special offers or news and/or updates to our Website, please email us at webmaster@caplink.ca.
You should be aware that non-personal information and data may be automatically collected through the standard operation of our Website’s internet servers or through the use of “cookies”. We use cookies and similar tracking technologies to track the activity on our Website and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we may use:
As with most other websites, We collect and use the data contained in log files. The information in the log files may include your IP address, your ISP, the browser you used to visit Our Website, the time you visited our Website and which pages you visited throughout our Website.
Customer information is a valuable business asset. If for any reason We transfer or divest ourselves of our business assets, our customer information may be transferred as one of these business assets. We will provide notice before your Personal Information is transferred and becomes subject to a different privacy policy.
Under certain circumstances, We may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
We may also release such information if we feel it is necessary in order to protect our rights or the rights of our customers, affiliates, partners, or any other party, and for purposes of protection from fraud and credit risk. We may disclose your Personal Information in the good faith belief that such action is necessary to:
The Website may contain links or references to other websites to which this Privacy Policy does not apply. These sites are not owned or controlled by us and We are not responsible for the collection, use and disclosure of personal information or the privacy practices of other organizations or other websites to which our site may refer visitors or provide links for. When submitting Personal Information on such other websites, we encourage you to read the privacy policy of those sites.
Our Website does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our servers.
Consent to the collection, use and disclosure of Personal Information may be given in various ways. Consent can be expressed (e.g., orally, electronically or on a form you may submit, or implied (e.g., when you provide information necessary for a service you have requested, or in some circumstances where notice has been provided to you about our intentions with respect to your Personal Information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided). Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with Personal Information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Policy, if applicable, or as otherwise described at the time of collection. You may withdraw your consent to our collection, use and disclosure of Personal Information at any time, subject to contractual and legal restrictions and reasonable notice, however, please note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our services.
We do not collect, use or disclose your Personal Information other than as described in this Privacy Policy without your consent, unless permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example in response to a court order or subpoena, to comply with local or federal regulations, or to collect a debt owed to us.
If you are an individual resident of the European Economic Area (EEA), you may have the following data protection rights:
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. You may be required to identify yourself as a person to which the GDPR is applicable in order for us to extend GDPR-mandated privacy requirements to you, and we reserve our right to deny provision of our services to you if we in our sole discretion determine that we want to provide the services only to persons resident outside the European Economic Area (“EAA”). If you are a resident of the EEA and believe we maintain your personal data subject to the General Data Protection Regulation (GDPR), you may find out more information, including about the complaint procedure, here; https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en.
If you are from the European Economic Area (EEA), our legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the personal data we collect and the specific context in which we collect it.
We may process your personal data because:
We will retain your Personal Information (aka “Personal Data”) only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We may also retain Other Information for internal analysis purposes. Other Information is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside Canada and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. Although we take standard precautions to safeguard your Personal Information, when you voluntarily disclose personally identifiable information (e.g., name, e-mail address, telephone number, etc.) on our Website which does not encrypt or otherwise secure that information other than by standard web server technology, along with any substantive information disclosed in your communication, this Personal Information may be subject to unauthorized collection by third parties and that unauthorized activity is beyond our control.
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions about this privacy statement, the practices of this site, or your dealings with the Website, you can contact us at webmaster@caplink.ca, or at our above-noted mailing address. Any dispute arising between you and us with respect to privacy is subject to any applicable terms and conditions of use of the Website, and this Privacy Policy, including limitations on damages, arbitration, and jurisdiction.
The foregoing policies are effective as of 07/12/2020. This statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights in or on behalf of any party.
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