Privacy Policy

1 Introduction

The Canadian Mortgage Relief Program (“CMRP”, “we”, “our”, or “us”) is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (cmrprogram.ca), use our services, or interact with us through third-party platforms including Meta (Facebook and Instagram).

This policy is governed by Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and all applicable provincial privacy legislation.

CMRP is a private mortgage rate comparison and monitoring service. We are not a mortgage brokerage, lender, or financial advisor, and we are not affiliated with any Canadian government program. All mortgage professionals who interact with clients through our program are independently licensed by the applicable provincial regulator (e.g., FSRA in Ontario).

Our designated Privacy Officer is accountable for our compliance with this policy and applicable privacy laws. To reach the Privacy Officer, see Section 17.

2 Information We Collect

Information You Provide

When you submit a form, use our online tools, or interact with our chat features, you may choose to provide:

• Name and contact information (email address, phone number)
• Mortgage-related details such as your mortgage goal, balance, renewal date, term preference, and general financial ranges (e.g., credit score bracket, income range)
• Messages and responses you provide during interactions with our website features

Information Collected Automatically

When you visit our website, certain information is collected automatically through cookies and similar technologies:

• IP address, browser type, device type, and operating system
• Pages visited, referring URLs, and interactions with site content
• Information collected by cookies and tracking pixels (see Section 10)

Information from Third-Party Platforms

If you submit a form through a third-party advertising platform (such as Meta Lead Ads), we receive the information you provided in that form, which may include your name, email address, phone number, and any custom responses.

3 How and Why We Use Your Information

We collect and use personal information only for the purposes identified at or before the time of collection. These purposes include:

• Comparing mortgage rates and presenting relevant options based on your situation
• Connecting you with a licensed mortgage professional who can assist with your needs
• Responding to your inquiry and following up regarding the services you requested
• Operating and improving our website, tools, and services
• Measuring the performance of our advertising and marketing efforts
• Complying with applicable legal and regulatory requirements

We do not use your personal information for purposes unrelated to those described above without first obtaining your consent.

4 Legal Basis for Processing

We process your personal information on the following legal bases under PIPEDA:

• Consent: You provide consent when you submit a form, check a consent box, or voluntarily provide information through our services. You may withdraw consent at any time (see Section 12).
• Fulfillment of service: Processing that is necessary to respond to your inquiry and deliver the services you requested.
• Legal obligation: Where required by Canadian law or regulation.

5 Sharing of Information

We may disclose your personal information to the following categories of recipients, solely to provide and support the services you requested:

• Licensed mortgage professionals: To connect you with a qualified, independently licensed agent who can assist your mortgage application
• Service providers: Third-party vendors who assist us with lead management, communications, analytics, and website operations. These providers are contractually required to protect your information and may only use it to perform services on our behalf.
• Advertising platforms: We share limited interaction data (such as page views) with advertising platforms to measure and optimize our marketing campaigns
• Legal requirements: Where required by law, regulation, court order, or governmental authority

6 Meta (Facebook & Instagram) Disclosure

In accordance with Meta's platform policies:

• If you submit information through a Meta Lead Ad, your data is governed by both this Privacy Policy and Meta's Privacy Policy (facebook.com/privacy/policy).
• We use information collected through Meta lead forms solely to respond to your mortgage inquiry and provide the services you requested. We do not repurpose this data without your separate consent.
• We use Meta tracking technologies on our website to measure advertising performance. These tools may collect information such as page views, browser information, and IP address.
• Our use of Meta's business tools is governed by Meta's Business Tools Terms (facebook.com/legal/terms/businesstools).
• We honour data deletion requests received from you or from Meta regarding Lead Ad data (see Section 13).

7 International Data Transfers

Our primary servers are located in Canada. However, some of the service providers we use to operate our website and services may process data in other jurisdictions, including the United States.

When personal information is transferred outside of Canada, it may be subject to the laws of those jurisdictions. We take commercially reasonable steps to ensure that all service providers maintain data protection standards consistent with Canadian privacy legislation.

8 Data Retention

We retain your personal information only as long as reasonably necessary to fulfill the purposes for which it was collected, including:

• To provide the services you requested and follow up on your inquiry
• To comply with our legal and regulatory obligations
• To resolve disputes and enforce our agreements

As a general practice, lead inquiry data is retained for up to 24 months from the date of collection, unless you request earlier deletion. Consent records may be retained for up to 36 months as required for CASL compliance. After the applicable retention period, data is securely deleted or anonymized.

9 Data Security

We take the security of your personal information seriously and implement reasonable administrative, technical, and physical safeguards designed to protect your data from unauthorized access, use, alteration, disclosure, or destruction.

These measures include industry-standard encryption for data in transit, restricted access controls, and regular review of our security practices.

While we strive to protect your personal information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, but we are committed to maintaining a level of protection appropriate to the sensitivity of the information we handle.

10 Cookies & Tracking Technologies

Our website uses cookies (small text files stored on your browser) and similar tracking technologies. These fall into the following categories:

• Essential cookies: Required for the website to function properly, such as maintaining your session and protecting form submissions. These cannot be disabled without affecting site functionality.
• Advertising and analytics cookies: Used by third-party advertising platforms to measure site traffic, track page views, and evaluate advertising performance. These cookies may collect information such as your IP address, browser type, and pages visited.

Managing Your Cookie Preferences

• You can disable or delete cookies at any time through your browser settings
• To opt out of interest-based advertising, visit the Digital Advertising Alliance (aboutads.info) or the Digital Advertising Alliance of Canada (youradchoices.ca)
• To manage Meta advertising preferences, visit Meta Ad Preferences (facebook.com/adpreferences)

11 Electronic Communications (CASL)

We comply with Canada's Anti-Spam Legislation (CASL) for all commercial electronic messages:

• We only contact you electronically (email, SMS) after you provide express consent, such as submitting an inquiry form with a consent checkbox.
• Your consent relates to the specific inquiry you submitted. We do not use your contact information for unrelated marketing without obtaining separate consent.
• Every commercial message we send identifies our organization, includes our contact information, and provides a clear and working unsubscribe mechanism.
• Unsubscribe requests are processed within 10 business days.
• If you inquire but do not proceed with a service, implied consent to receive follow-up communications expires 6 months after your inquiry, in accordance with CASL.

12 Your Rights

Under PIPEDA and applicable Canadian privacy laws, you have the right to:

• Access the personal information we hold about you
• Correct any inaccurate or incomplete information
• Request deletion of your personal data (see Section 13)
• Withdraw consent to the collection, use, or disclosure of your information at any time
• Opt out of commercial communications at any time
• File a complaint about our privacy practices (see Section 15)

To exercise any of these rights, contact our Privacy Officer at privacy@cmrprogram.ca. We will respond within 30 calendar days. There is no fee for making a request.

13 Data Deletion Requests

14 Children's Privacy

Our services are intended for individuals aged 18 and older. We do not knowingly collect personal information from anyone under 18. If you believe a minor has submitted information through our website, please contact our Privacy Officer and we will promptly delete it.

15 Complaints

If you have concerns about how we handle your personal information:

1. Contact us first: Email our Privacy Officer at privacy@cmrprogram.ca. We will investigate and respond within 30 days.
2. Escalate if unsatisfied: You have the right to file a complaint with the Office of the Privacy Commissioner of Canada (1-800-282-1376 | priv.gc.ca).

16 Changes to This Policy

We may update this Privacy Policy from time to time. When we do, the “Last updated” date at the top of this page will be revised. Material changes will be noted on this page. Your continued use of our website and services after changes are posted constitutes your acceptance of the updated policy. We encourage you to review this page periodically.

17 Contact Us