1. Information We Collect
We collect personal information that is necessary to provide mortgage brokerage services and operate our business. This includes:
(a) Identity Information: your full name, date of birth, government-issued identification numbers, and Social Insurance Number (SIN) where required for mortgage applications;
(b) Contact Information: home address, mailing address, email address, phone numbers;
(c) Financial Information: income, employment details, assets, liabilities, credit score, banking information, tax returns, and other financial documents required to assess mortgage eligibility;
(d) Property Information: property address, purchase price, appraised value, property type, and existing mortgage details;
(e) Technical Information: IP address, browser type, pages visited, time spent on pages, and cookie data collected through our website;
(f) Communication Records: records of your communications with advisors at Mortgage Squad Advisors, Maya (our AI assistant), and our customer service team.
2. How We Use Your Information
We use your personal information for the following purposes:
(a) Mortgage Services: to process your mortgage application, assess your eligibility, submit your application to lenders, and manage your mortgage file through funding;
(b) Communications: to contact you regarding your application, renewal reminders, rate alerts, and important service updates;
(c) Legal Compliance: to comply with FINTRAC anti-money laundering obligations, FSRA licensing requirements, and other applicable laws;
(d) Service Improvement: to improve our website, services, and the Maya AI platform;
(e) Marketing: to send you information about our products and promotions where you have consented to receive such communications. You may withdraw consent for marketing communications at any time by clicking "unsubscribe" in any email or contacting us directly.
3. Disclosure of Your Information
We do not sell your personal information. We may share your information with:
(a) Mortgage Lenders: when you authorize us to submit your application to lenders for assessment and approval;
(b) Service Providers: third-party companies that assist us in operating our business, including transactional email providers, SMS providers, hosting and infrastructure providers. All service providers are bound by confidentiality agreements and operate within our own client management platform;
(c) Professional Advisors: lawyers, accountants, and other professionals where required for your transaction;
(d) Regulatory Bodies: FSRA, FINTRAC, and other regulators as required by law;
(e) Legal Requirements: where required by court order, subpoena, or other legal process. We do not disclose your information to foreign governments or sell data to advertisers.
4. FINTRAC Compliance
Mortgage Squad Advisors is a FINTRAC reporting entity. While our brokerage license is provincial (FSRA, Ontario), our anti-money-laundering obligations are federal under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).
These obligations require us to: verify the identity of all clients using a FINTRAC-acceptable method; screen against Politically-Exposed-Person and sanctions lists; assess transaction risk on every file; keep records for the FINTRAC-required period (a minimum of five years for transaction records); and report certain transactions to FINTRAC as required by law, including large cash transactions and suspicious transactions.
FINTRAC verification is a legal requirement and cannot be waived. Personal information collected for FINTRAC purposes is used only for compliance and is not used for marketing.
5. Data Storage and Security
Your personal information is stored on secure servers located in Canada. We implement industry-standard security measures including: TLS encryption for all data transmitted through our website; encryption of stored personal and financial data; role-based access controls limiting who within Mortgage Squad Advisors can access your information; audit logging on sensitive operations; and regular security reviews.
While we take reasonable precautions to protect your information, no transmission over the internet is completely secure. We cannot guarantee the security of information transmitted to our website and you do so at your own risk.
6. Privacy Breach Notification
In the event of a privacy breach involving your personal information that, in our reasonable assessment, creates a real risk of significant harm (RROSH) to you, we will notify you and the Office of the Privacy Commissioner of Canada (OPC) without unreasonable delay, as required by PIPEDA Section 10.1.
Notification will include a description of the circumstances of the breach, the personal information affected, the steps we have taken to reduce risk of harm, and steps you can take to protect yourself. For Quebec residents, additional notification obligations under Law 25 apply and will be followed.
7. Maya AI Platform
Our website and customer portals include Maya, an AI-powered mortgage assistant. When you interact with Maya — by chat, voice, SMS, WhatsApp, or email — the following applies:
(a) No binding advice: Maya does not give binding mortgage advice, lock rates, or commit funds. Every binding decision involves an FSRA-licensed mortgage advisor. A structural compliance guard reviews each Maya reply before it is shown to you and rewrites any phrasing that would cross into binding advice;
(b) Typed memory: Maya remembers facts about your file (preferences, goals, life events). Sensitive memories (mental-health context, immigration status, hardship) are flagged and redacted from administrative search, exports, and most read surfaces. You can review and request correction of any memory;
(c) Voice recording consent: voice calls with Maya are recorded for quality and compliance audit, with the consent prompt at call start. Recordings carry strict retention (default 90 days, configurable) and every staff playback is logged. You can request your own transcript at any time via the share-link feature on /brokerage/maya/recordings or by emailing info@mortgagesquad.ca;
(d) No third-party training: Maya conversations are processed by third-party AI vendors (see /sub-processors) under inference-only contracts that prohibit use of your conversation for model training;
(e) Right of access + erasure: you can download a complete copy of your Maya conversations, memory, and call records from /client/data, or request deletion from the same page.
9. Your Rights Under PIPEDA and Law 25
You have the following rights regarding your personal information:
(a) Right to Access: you may request a copy of the personal information we hold about you. For Maya conversation, memory, and call data, this is now self-serve at /client/data — the export is generated instantly as a downloadable JSON file. For other records, email info@mortgagesquad.ca and we'll fulfill within 30 days;
(b) Right to Correction: you may request correction of inaccurate information by contacting your advisor or emailing info@mortgagesquad.ca;
(c) Right to Erasure: you may request deletion of your personal information at /client/data (self-serve request, executed within 30 days subject to legal-hold exceptions for active mortgage applications and FINTRAC retention obligations);
(d) Right to Withdrawal of Consent: you may withdraw consent to certain uses of your information, subject to legal and contractual restrictions;
(e) Right to Complain: you have the right to complain to the Office of the Privacy Commissioner of Canada if you believe we have mishandled your personal information. To exercise any of these rights, contact us at info@mortgagesquad.ca or by mail at 310-3100 Steeles Ave W, Vaughan, ON L4K 3R1.
10. Retention
We retain your personal information for as long as necessary to fulfill the purposes described in this policy and to comply with legal obligations. Mortgage application files are retained for a minimum of seven years in accordance with FSRA requirements.
FINTRAC records are retained for a minimum of five years. Marketing consent records are retained for three years after last contact.
11. Changes to This Policy
We may update this Privacy Policy from time to time. The date of the most recent revision is shown at the top of this page.
Material changes will be communicated by email to active clients. Continued use of our services after changes constitutes acceptance of the updated policy.
12. Sub-processors and Cross-Border Data
We use third-party service providers ("sub-processors") to deliver specific functionality — AI inference, voice transcription, email, telephony, hosting, and analytics. The complete current list, including each provider's category, purpose, the data they access, and the region they operate from, is published at mortgagesquad.ca/sub-processors and is updated BEFORE any new sub-processor touches customer data.
Enterprise customers receive 30 days' advance notice of material sub-processor changes via the email on file. Some sub-processors (notably our AI inference and email providers) process data from US-based infrastructure on inference-only contracts that prohibit retention or training.
Under PIPEDA Principle 4.1.3, we remain accountable for your information regardless of who processes it, and contractually require all sub-processors to provide comparable protection. If you object to a particular sub-processor, contact info@mortgagesquad.ca — we'll discuss alternatives or, where no alternative is operationally feasible, work with you on termination.
13. Self-Serve Data Tools
Authenticated clients have one-click access to:
(a) Data Export at mortgagesquad.ca/client/data — generates a complete JSON download of your profile, conversations, memory, intents, recording metadata, outreach history, and consents. Instant, no waiting period;
(b) Deletion Request at the same page — submits a verified deletion request that runs within 30 days, subject to identity verification and legal-hold exceptions for active mortgage applications.
Both tools are available without contacting support. For data we hold that's not surfaced in the self-serve export (paper records, internal compliance notes), email info@mortgagesquad.ca and we'll fulfill within the PIPEDA 30-day window.
Contact
- Privacy Officer · Mortgage Squad Advisors (Ontario) Inc.
- 310-3100 Steeles Ave W, Vaughan, ON L4K 3R1
- Email: info@mortgagesquad.ca
- Phone: (905) 553-8550
- You also have the right to contact the Office of the Privacy Commissioner of Canada at priv.gc.ca or 1-800-282-1376.