PRIVACY POLICY

At Rouge Services Corporation, we are committed to protecting the privacy and confidentiality of the personal information of our clients, both mortgagor or potential mortgagees or investors in a mortgage product (individually, the “Client” and collectively, the “Clients”).  As financial service providers, we have a professional obligation to maintain confidentiality with respect to the information we receive from the client. The purpose of our privacy policy is to advise clients as to why we ask for personal information, how we use it, what safeguards we employ, and how to contact us with privacy-related matters, as well to keep up with provincial regulators compliance requirements.  Rouge Services Corporation reserves the right to amend the Privacy Policy at any time. Our full Privacy Policy is also available and accessible to our clients on our web site at:

www.rouge.mortgage/privacypolicy

What Is Personal Information?

In this Privacy Policy, “Personal Information” means information that is gathered in connection with an application, pre-approval, request for information for a mortgage(s) or loan(s) and creditor life insurance or other product, the servicing of any mortgage or any activity related to the initiation, application or completion of the acquisition of any mortgage or mortgage based product through Rouge Services Corporation, or affiliates and that is provided to, or collected by, Rouge Services Corporation, and its staff or by its mortgage agents, mortgage brokers, associates, and affiliates on Rouge Services Corporation’s behalf. Examples of personal information include, but are not limited to, address(es), Social Insurance Number(s), date(s) of birth, phone numbers, email address(es), income document(s), health history, CRA notices, bank statement(s), proof of down payment(s), existing mortgage(s) details, property tax statement(s), credit report(s), appraisal(s), fire insurance policies, signed documents, photo identification(s), relationships with third parties (lawyers, accountants, insurers).

Why Rouge Services Corporation Collects Personal Information?

Rouge Services Corporation collects and uses Personal Information for the following purposes, and its collection must be limited to these purposes:

  • Provide mortgage administering services 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 Rouge Services Corporation or its affiliates that may be of interest to the Client;
  • Mortgage loan administration and servicing, including services for third party mortgage lenders, and investors not serviced with Rouge Services Corporation which may be associated with Rouge Services Corporation. Reporting and servicing mortgage loan transactions for Rouge Services Corporation and its affiliates.
  • Checking Client credit worthiness through credit bureau inquiry and personal information agents who have information on a Client’s financial position, which may include social media sources and enquiry with employers (employment and income verification) and other third party sources;
  • Advising Clients of financial options, as well as ongoing developments of the mortgage market, credit and related insurance and industry;
  • Internal auditing, and by third party audit providers, the services provided to our Clients;
  • Compliance with all municipal, provincial, federal and other applicable laws relating to mortgage administering, lending and investment;
  • Such other specific purposes which are communicated to the Client by a member of Rouge Services Corporation before collection of such Personal Information

Except when otherwise permitted by law, Rouge will only use a Client’s Personal Information for the purposes identified to the Client by the Rouge Privacy Policy. All Clients must be referred to the Privacy Policy and the related privacy code. When Personal Information is to be used for a purpose not identified in the Privacy Policy, the Broker or Agent must inform the Client, prior to taking any action, and also obtain Client written consent.

How Do We Collect Personal Information?

We collect information from the Client(s), employers, social media, data and credit collection agencies.  With the Client’s consent, we may also obtain information directly from other third parties to help us determine eligibility for various financial products and services. For credit matters, for example, it is essential that we know the clients’ financial worth as well as the clients’ credit record. We may contact other lenders, financial institutions, credit bureaus, data agencies, social media, and employers.  Consent is therefore necessary because without it, we will not be able to carry out the appropriate duties of mortgage administering services.  Consent must be obtained using our forms used for specific products or occasionally on a separate form we have approved (e.g. Mortgage Application(s), Credit Consent Form, the Client Agreement from  the Rouge Services Corporation website, or Know Your Client form).

Consent

A Clients provision of Personal Information to Rouge Services Corporation or its affiliates means that they have agreed and consented that Rouge Services Corporation can collect, use and disclose such Personal Information in compliance with our Privacy Policy. Rouge Services Corporation 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, but is not limited to, 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, while still in compliance with law or regulatory authorities.

The most common method we use to obtain a Client’s consent is by way of the Client’s consent as confirmed by the Rouge Mortgage Application, Know Your Client Form, the Client Agreement found on the Rouge Services Corporation website or Credit Consent Form. Occasionally, we may accept other forms of authorization such as email/fax authorization or verbal consent, for an existing Rouge Services Corporation Client only, on an exception basis, granted from the administrator management (these exceptions must obtain email confirmation from Rouge Services Corporation key personnel). Consent must be on Rouge forms or a form we accept as equivalent.

The Client(s) may withdraw their consent at any time, by written notice, subject to any legal or contractual restrictions (which will include the inability to withdraw consent needed for servicing). A Client’s refusal to provide, or subsequent withdrawal of, his or her consent may affect Rouge Services Corporation’s ability to provide the Client with mortgage services, and services may not be provided absent current and effective consent. A member of Rouge Services Corporation will inform the Client of the implications of such withdrawal as soon as we are informed. To withdraw consent, a Client will need to contact the Chief Privacy Officer/Principal Broker in writing at:

Attention:

Daniel Stein, Principal Broker

Rouge Services Corporation

Email: [email protected] OR Fax 1-866-224-4096

35 West Pearce St. Unit #1, Richmond Hill, Ontario L4B 3A9

Use and Disclosure of Personal Information

Rouge Services Corporation uses a Client’s Personal Information to provide financial advice and services to the Client, to administer its database, to include Clients in direct marketing activities, to service the mortgage and other products, or to allow third parties to do so, and for the other uses described above under the heading “Why Rouge Services Corporation Collects Personal Information”. Under certain circumstances, Rouge will disclose a Client’s Personal Information to third parties in accordance with the Privacy Policy.

Under certain circumstances, Rouge may disclose Personal Information such as:

  • When it is required or authorized by law to do so, for example if a court issues a subpoena;
  • When a Client has consented to the disclosure;
  • When mortgage services are provided to a Client requiring Rouge to give Client Personal Information to a third party (for example, to a lender in a real estate mortgage transaction);
  • Where it is necessary to pull a credit bureau or to perform an investigation, such as an employer investigation, for purposes of processing a mortgage transaction;
  • If Rouge engages a third party to provide administrative support services (such as a technology partner, CRM system provider, cloud back up provider, computer back-up services, shredding or archival file storage), and the third party is bound by the Privacy Policy;
  • Protection of public interests, including the denouncement of criminal activity such as fraud or money laundering. In such cases, authorities may be 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

Rouge Services Corporation limits the collection of a Client’s Personal Information to that which is necessary for the purposes identified in the Privacy Policy (may be amended from time to time), or for any other additional purpose identified to the Client. 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 and as set out in the Privacy Policy.

Rouge Services Corporation will retain Personal Information only for as long as it is needed, to fulfill the purposes for which it was obtained and to meet our professional requirements as set out by the governing regulatory bodies and/or any other legal obligations.

Accuracy

Rouge Services Corporation 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. The Client is responsible to forward changes or updates in their information to Rouge for record purposes.

Honesty

Regulated persons and entities must conduct their activities in a truthful, clear and transparent manner. They must not mislead, hide or obscure material information.

Safeguards

Rouge Services Corporation 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 Rouge Services Corporation and its affiliates. Rouge Services Corporation uses various methods to safeguard personal information, including physical security (Office Firewall System), computer and electronic security (Multi-Factor Authentication for Email Systems), destruction of information no longer needed, and contractual protections with third party data processors (CRM System(s) providers).

Protection

Client lists are never passed onto third parties other than Rouge affiliates. Rouge employees, Brokers and Agents are expected to abide by the obligations and requirements outlined in the Privacy Policy and respect the confidential nature of Client Personal Information. Only employees, contractors and associates who require access to a file, as part of their work, will have access to this information.

Accountability, Openness and Client Access

Rouge Services Corporation is responsible for the Personal Information under its control and has appointed a Chief Privacy Officer (Principal Broker – Daniel Stein) to oversee the efforts to comply in all material respects with the applicable privacy legislation and the terms of our Privacy Policy. The Chief Privacy Officer and those designated by the Chief Privacy Officer address and investigate questions or concerns regarding a Client’s Personal Information. Any privacy enquiry or issue must be made known to the Chief Privacy Officer in a timely manner.

If requested, Rouge Services Corporation will provide a Client access to their Personal Information. The Client may correct or amend any verified inaccuracies in the Client’s Personal Information. Rouge can limit, and has the right to refuse a Client request for access to Personal Information if:

  • The information is protected by legal privilege;
  • Granting access would reveal confidential commercial information;
  • The information was collected for purposes related to the detection and prevention of fraud;
  • The information was generated in the course of a formal dispute resolution process;
  • The information would likely reveal personal information about another individual;
  • The request is vexation or frivolous;
  • To protect Rouge’s rights and property;

all in accordance with Rouge’s Privacy Policy.

Changes to Privacy Policy

Rouge Services Corporation will occasionally review and revisit its privacy practices and the Privacy Policy. Mortgage Brokers and Agents, as well as Clients, are required to stay up to date on the Privacy Policy and its related operational practices. 

PROTECTION OF DATA

Head Office Protection of Data

Rouge Head Office will take reasonable steps to secure the Personal Information in the Client files. Scanned documentation must be adequately protected and catalogued by the Broker or Agent, although Rouge will review the files to ensure that they have been completed. All Client and Personnel records will be kept in secured electronic format on Filogix Data Exchange or other Rouge CRM platforms.  All computers will operate on a secure network firewall protected at Rouge head office, will be password protected, will have multi-factor authentication email login, and data will be backed up on a regular basis by a third-party source.