This privacy policy is for Scarlett Brokers (Mortgage Brokers) and Users (Mortgage Applicants): Updated

Scarlett Network is offered by Axiom Innovations Inc.

Axiom Innovations Inc. (Axiom Innovations Inc. is hereinafter referred to as “we”, “us”, and “our”) is committed to the privacy and security of your personal information. This privacy policy (or “Policy” for short) describes how we collect, use, disclose and otherwise process your personal information, how we protect it and the controls you have over it.

This Policy is incorporated into, and is subject to, our Terms of Service. Capitalized terms used but not defined in this Policy have the meaning ascribed in our Terms of Service. This Privacy Policy applies to the Personal Information that is provided during your interaction with our Services. In the course of using our Services, you may use a third party’s intellectual property, tool or resources, including for the purposes of interacting with your mortgage broker and their team (“Broker”) or for the Broker interacting with the User (“Applicant”), and such third party’s privacy policy may also apply to you.

This Policy does not extend to websites, mobile applications or other services of third parties. We are therefore not liable for their privacy policies, procedures and practices.

By using the Services, by communicating with us or by agreeing to receive communications from us such as commercial electronic messages, you accept the terms and conditions of this Policy. If you do not agree with the terms and conditions of this Policy, or if you lack the capacity or authority to agree to these terms and conditions, do not access or use the products or Services that require access to your personal information.

Changes to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time in order to ensure compliance with the Personal Information Protection and Electronic Documents Act S.C. 2000, c.5.. If we modify the Policy, we will make it available through our website, indicate the date of the latest version, and comply with applicable laws. Your continued use of our website after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy. If you disagree with any changes made to the Policy, please cease to use the Services. Additionally, if you restart using the Services, you are considered to have accepted the Policy then in effect.

How we Collect Information

We collect, use and disclose personal information in order to effectively fulfill the purposes of this policy and provide products and Services. Some personal information is provided to us voluntarily by you (for example, when you create an account in order to use the Services) while some personal information is collected automatically (for example, when your browse the Site, cookies are placed on your Device (as defined in Section 3 below).

More precisely and without limitation, we collect your personal information with your consent in the following circumstances:

1. When you create an account in order to use the Services;
2. When you request our Services, such as when you submit a mortgage application, or when you upload documents or information to your account;
3. When you communicate by engaging with the Website for various purposes, including account openings, registration or submission of other information to us; and
4. When you interact with the digital content on the website;
5. When you participate in a contest or in a survey;
6. When you post comments on the website; and
7. When you choose to give us permission to access your personal information from third party websites (for example, by linking to social media networks). When you do so, you allow us to collect information based on your settings and in accordance with the privacy policies of such Third Party Services. It is your responsibility to control your settings and to read and understand those policies.

What Information Is Collected

Personal Information

For the purpose of this Policy, “personal information” means information about an identifiable individual pursuant to the Personal Information Protection and Electronic Documents Act S.C. 2000, c.5.

For example and without limitation, we consider your given name, surname, date of birth, postal address, telephone number, mobile phone number, email address, income, credit history or other financial information and credit card information as personal information.

Personal Information does not include business contact information, such as the name, title, business address or telephone number of an employee of an organization. In order to provide you with the Services, we may be required to obtain from you sensitive personal information such as financial information (for example, your income, your assets, and your indebtedness etc.), information from your employer (for example, an employment statement). We may also ask for your Social Insurance Number (SIN) so that we can provide your information to a credit reporting agency in order to perform a credit check. The SIN is the best way to ensure that the information we are provided by the reporting agency actually refers to you. Providing your SIN assists us with accurate and timely processing of your application. This sensitive personal information is only collected to fulfill the Services we provide and will only be collected when necessary.

Information Collected Automatically

Like most modern Internet sites and mobile applications, the Website uses cookies to record user browsing activity, such as pages visited, or technological information such as the Internet browser and operating system used to visit the Website. The use of cookies and similar tracking technologies enables us to improve the Website’s performance, remember your preferences/settings, offer you an optimal experience with the Site or the App, personalize the Services and, in accordance with applicable laws, send you advertisements tailored to your interests.

A cookie is an alphanumeric online identifier that is set on your computer, tablet or mobile (“Device”) when you use the Website.

Cookies can be set by us on your Device or by a third party (such as our partners).

The website contains content from and hyperlinks to certain third parties’ websites, locations, platforms, and services (“Third Party Services”). In addition, the Website contains cookies operated by third parties. For example, we use certain third party analytics services, such as Google Analytics and other integrated services, including the collection of information via cookies. Similarly, ad serving services, advertisers, and other third parties may use tracking technologies on the Website and on the Third Party Services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third Party Service or third party device after you have left the Website.

The Website contains social media plugins provided by social media platforms in order to allow you to interact with us on these platforms. By browsing the Website, your browsing information may be transferred directly to the relevant social media platform, even without direct interaction on your part, due to the sole presence of the buttons on the Website. These cookies are not under our control. Please consult the privacy policies of each of these social media platforms to know more about their use of cookies and other tracking technologies and how they work.

In general, the information collected by cookies is not considered personal information since it cannot be used to identify you. You may set your Internet browser to reject cookies if desired; however, this may result in loss of functionality of certain features of the Website.

Information About Someone Else

As set forth in the Terms of Use, your account is intended for your use and information between accounts is not shared, even if the accounts are both involved in the same transaction. Therefore, if you wish to co-purchase a property with another individual, you will each need to upload documents to your individual accounts, since the documents in one account are not accessible to another. YOU MUST ENSURE THAT YOU HAVE THE REQUIRED CONSENT OF YOUR CO-PURCHASER PRIOR TO SHARING ANY OF THEIR PERSONAL INFORMATION WITH US.

Children’s Information

We do not knowingly collect personal information from children through our Services. If you are a minor under the laws applicable to your place of residence, please do not submit to us any personal information without the express consent of a parent or guardian.

How we Use Information

Information may be used in a variety of ways which are in keeping with the intent behind the collection of information. All personal information collected by us is reasonable and necessary to fulfill a stated purpose or Service. For example, said use may include connecting you to your broker, or if you’re a broker, connecting you to a borrower. Further to the above, we take steps designed to ensure that only employees or brokers who need access to your personal information to fulfill their duties will have access to it. We may use your personal information for several purposes including to:

1. Manage the account creation process on the Website and, more generally, manage your account;
2. Deliver the products and services you have requested through the Services;
3. Design, maintain, analyze, manage, improve, market and provide products and services via the Website;
4. Help us perform transactions and verify your identity with the transaction you have requested;
5. Provide access to the Website;
6. Respond to your queries, questions and comments;
7. Perform quality assurance, marketing and other business analysis;
8. Connect you to your broker, or if you are a broker to connect you with an applicant;
9. Communicate with you about changes to our policies;
10. Send you surveys with regards to the Services, namely satisfaction surveys, in accordance with applicable laws or with your consent (if required);
11. Understand your needs and interests and provide you with optimal services and personalized advertisements, services and products by performing profiling, where permitted under applicable laws or with your consent (if required);
12. Improve the Website performance, respond to your requests regarding the Website, remember your preferences/settings with regards to the Site and the App;
13. Send you specific information, promotional and marketing communications about us or third party products and services (for example, offers, discounts, newsletters and birthday communications), where permitted under applicable laws or with your consent (if required);
14. Protect against error or fraud;
15. Comply with legal and auditing requirements;
16. Investigate breaches of the Terms of Service or the Policy;

Disclosure of Personal Information

In certain circumstances or in order to perform the Services, we may disclose your personal information with:

Financial Institutions:

In order to provide you with the Services and the products and services that you have requested, we may share your personal information with financial institutions;

Promotional Partners:

We may share your personal information with third parties who may associate themselves with us for any activities such as contest and other promotions. We do not share sensitive personal information such as financial information with promotional partners;

An Acquirer, Successor or Assignee

In the event of change of ownership, sale, merger, liquidation, reorganization, acquisition of Axiom Innovations or its Scarlett Network product, in whole or in part, or in the event of any other business transactions or bankruptcy, your personal information may be transferred as part of the transaction;

Law Enforcement, Governmental and Administrative Entities

We may disclose your personal information with law enforcement, government and administrative entities if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facility valid court order, judicial or other governmental subpoena or warrant, or to otherwise cooperate with law enforcement, governmental and administrative entities;

Social Media Networks or other Service Providers

We may share your personal information with social media networks and other service providers to use their marketing tools for the purposes of target and look alike marketing. We do not share sensitive personal information such as financial information with social media networks or other service providers for marketing purposes.
Please note that once we share your personal information with a third party, it may become subject to such third party’s privacy practices. Please note that we make commercially reasonable efforts to have your personal information used by third parties in a manner that is consistent with this Policy.

Storage of your Personal Information

While your personal information will be collected and stored on servers in Canada, it may be disclosed to, stored and/or otherwise processed by third parties who are located in other countries. Regardless of where the processing of your personal information takes place, we will take steps to protect your personal information in accordance with this Policy, data protection laws, and where required by applicable laws, recognized data transfer mechanisms. While we use reasonable means to safeguard your personal information, it is subject to the legal requirements and governmental authorities of the foreign jurisdictions in which it is located.

Personal Information Security

We take the security of your personal information very seriously. We have adopted reasonable security procedures to help protect against loss or theft, unauthorized access, disclosure, copying, use, or modification to the personal information you provide to us. This includes physical, organizational and technical measures of protection.
While we strive to protect your personal information, we cannot guarantee or warrant the security of any personal information you disclose or transmit via our Services and cannot be responsible for the loss, theft, unauthorized access, disclosure, copying, use, or modification of your personal information, unless such acts are the result of our gross negligence or willful misconduct or unless otherwise provided by law.

Retention Period

We will retain your personal information only as long as is necessary for the fulfillment of the purposes outlined in this Policy or for a longer period if required or permitted under applicable laws. Please note that if you merely unsubscribe from marketing communications such as the newsletter, we may nonetheless continue to use your personal information for marketing and business analytics purposes, unless you withdraw your consent to this activity by following the procedure set out in the “Withdrawal of Consent” section of this Policy. Personal information that is no longer necessary for the fulfillment of the purposes outlined in this Policy will either be destroyed, erased or made anonymous within a reasonable retention period or as required under applicable laws.

Deletion of Information

Applicants may request their information to be deleted by contacting their mortgage broker. An applicant mortgage broker contact details are displayed on the home page of the mortgage application link. Ultimately it is the mortgage broker’s decision to accept the data deletion request based on the status of the application and the rules and regulations of their regulatory authorities.

Right to Consult and Correct Personal Information

You have the right to consult all personal information that relates to you and that is held by us, and to correct any such personal information that is inaccurate, incomplete or outdated.

Information stored in your account profile may be consulted through our Site and corrected directly by you if necessary.

Information collected by cookies is stored in cookie files located on your device, and thus can be accessed or modified by you without involving us.

For all other privacy-related requests, you may contact us via email using the contact information in the “Contact Us” section of this Policy. Depending on the nature of your request, a reasonable fee may be required before we transcribe, reproduce, or transmit your personal information.

Withdrawal of Consent

You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us via email using the contact information in the “Contact Us” section of this Policy. However, before we implement the withdrawal of consent, we may require proof of your identity or quality.

In some cases, withdrawal of your consent to our collection, use or disclosure of personal information may mean that we will no longer be able to provide certain products or services to you, including access to the Site where the collection, use or disclosure of personal information is necessary for the products or services.

Contact

If you have any questions, comments, concerns or complaints about this Policy or your personal information, or to make a request to access your personal information or have it corrected, please communicate with our Privacy Officer by email using the following contact information:

Attention: Axiom Innovations, Privacy Officer
5160 Yonge St. Suite 1006, Toronto, ON, M2N 6L9
Email: support@scarlettnetwork.com
1.855.561.4399
[Last update: May 31, 2024]