Privacy Policy

Strive’s Commitment

Last revised: September 20, 2023

Strive Capital Corporation, its affiliates and subsidiaries (“Strive” or “we” or “our” or “us”) is committed to protecting your privacy and safeguarding the confidentiality of your personal information.

This Privacy Policy describes our personal information handling practices and is intended to assure you of our continuing commitment to protect the confidentiality of such personal information that we handle in the course of commercial activities.

Strive has established Fair Information Principles, contained within our Privacy Policy, that describe how we collect and use your information, how it may be shared and with whom, our security practices and your choices. These Fair Information Principles also explain the measures we take to safeguard your personal information and your right to access, update and amend that information.

What is Personal Information?

Personal Information (“PI”) is any information about an identifiable individual pursuant to applicable privacy laws. PI that we collect may include, but not limited to, your name, date of birth, gender, current or past home address, telephone numbers, email address, unique identification numbers such as government issued identification numbers, financial and banking records and information, credit information, personal references, past and present employment records, or any other personally identifiable information that you choose to provide to us or any information that we are required to obtain under any legislation.

Principles

Strive applies its Privacy Policy in accordance and compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), which outlines 10 Fair Information Principles that businesses must follow to protect PI.

Principle 1 – Accountability

We are responsible for your PI under our control and our Chief Risk Officer acts as our Chief Privacy Officer who is accountable for our compliance with the applicable privacy laws. Specifically, this entails the following:

• Ensuring that this Privacy Policy is up to date;
• Handling customer complaints and inquiries;
• Leading investigations for potential/alleged privacy breaches; and
• Ensuring compliance with ‘privacy best practices’.

Principle 2 – Identifying Purposes

You have the right to know why we need your Personal Information. The PI we collect from you must be for an identified purpose and we commit that the PI we collect will be used solely for the specific identified purposes. In the case of Strive, we collect and use your PI to determine your eligibility for mortgages, related products such as insurance, and other related mortgage services such as funding and servicing your mortgage loan.

Generally, most of your PI comes from your mortgage broker or if you applied online to Strive, then from you directly through application and supporting documentation. Your mortgage broker is also required to obtain your consent prior to sharing your PI with us, and our agreement with each mortgage broker requires that they obtain the requisite consent from you prior to sharing your PI with us. We also may obtain additional information with your consent (see Principle 3. below).

Specifically, given that our core business is mortgage lending, your PI is collected and used for the following purposes:

• To review your credit history (through tools such as credit reports), and specific financial information about you such as your earnings, assets, liabilities, monthly obligations and past repayment history, to evaluate your current and ongoing creditworthiness, to ensure that we keep this information updated (as needed) during the course of our relationship with you and to determine your eligibility for products and services.
• To verify your identity in each interaction with us, most commonly with questions and requests; and to check your name against Canadian and foreign watch and sanctions lists.
• To administer our financing programs, including the sale of individual mortgage loans to third-party regulated entities such as banks and for purposes of the securitization programs sponsored by Canada Mortgage Housing Corporation (“CMHC”) or other entities.
• To offer and administer mortgage life (and disability) insurance and similar related products relating to the loan (e.g., home warranty products).
• To renew or refinance existing mortgages, transfer / switch mortgages from another institution or fulfill payout and discharge requests.
• To pay municipal property taxes related to the mortgaged property, if applicable
• To protect you and us from error, and to detect and prevent fraud and other unauthorized or illegal activities.
• To collect outstanding debts.
• To provide you with physical or electronic updates and other information about your application or products with us. This will include providing you with annual mortgage statements and Strive marketing materials.
• To assess your suitability for any new non-mortgage products we may introduce.
• To advertise, market and promote our products and services that may be of interest to you.
• To collect demographic and/or geographic information which assists us in generating trends, statistics and market research for other business purposes.
• To comply with legal and regulatory requirements and for other purposes as otherwise required or permitted by applicable laws.

Principle 3 – Consent

We inform you of the purposes for the collection, use or disclosure of your Personal Information prior to collection.

Consent to the collection, use and disclosure of Personal Information may be given in various ways. Consent can be express or implied. In some circumstances, where notice has been provided to you about our intentions with respect to your PI and you have not withdrawn consent, you will be considered to have consented for the purposes identified and described to you. By submitting your PI to us or our service providers and agents, you consent to the collection, use and disclosure of such PI as described in this Privacy Policy or otherwise at the time of collection. If you provide us or our service providers and agents with the Personal Information of another individual, it is your responsibility to obtain consent from such person to enable us to collect, use and disclose such PI for the purposes set forth in this Privacy Policy.

We accept any of the following methods as indicating your consent for Strive’s existing and future collection, use and disclosure of your PI for the purposes identified in this Privacy Policy or in any document in which you expressly give your consent:

• Your unrestricted provision of information directly to Strive or through licensed agents or mortgage brokers who notify you, in advance of the collection of your PI, of the purposes for which your PI will be used and disclosed and the consequences of your granting consent.
• Your receipt of this Privacy Policy prior to your unrestricted provision directly to Strive or through licensed agents or mortgage brokers.
• Your express consent as obtained through an application process, or in a mortgage commitment, mortgage or related document.

As a consequence of your granting consent, we are able to collect, use and disclose the PI we have received for the purposes identified in this Policy.

This includes complementing the PI with additional information from other sources such as, Credit Reporting Agencies, public data and registries, your past and current employer, personal references and any other organizations with whom you have provided your consent to disclose PI to us.

In certain circumstances, as permitted or required by law, we may also collect, use or disclose information made available by you through public platforms (i.e., social media sites). For applications or loans submitted to Strive that involve another person, we also collect information from that person (i.e., your spouse or partner as a co-applicant and/or guarantors).

Your consent will always be obtained prior to using or disclosing your PI for purposes other than those for which it was intended.

You may withdraw your consent at any time by advising the Chief Privacy Officer of Strive in writing using the contact information listed at the end of this Policy. However, please note that the right to withdraw consent is not absolute; it is subject to contractual and legal restrictions and reasonable prior notice. If you withdraw your consent, we may be limited or unable to provide you with certain services or information.

To withdraw your consent from any electronic or other marketing communications, you may follow the unsubscribe instructions included in our electronic communications or contact us using the contact information at the end of this Privacy Policy. Important Note: Please note that you may continue to electronically receive transactional and mortgage account related communications from us electronically throughout your mortgage term with us.

Principle 4 – Limiting Collection

We will only collect PI that is limited to that which is needed for the identified purpose. While in general, most of the information we collect about you comes from a mortgage broker, we also will communicate with you directly and obtain information through various methods of communication.

Communication With You:

This includes, for example, telephone conversations where we may record and monitor both inbound and outbound customer calls for our mutual protection and to enhance customer service and/or monitor calls for quality assurance, security and ongoing training of our employees. In compliance with applicable privacy laws, customers will be informed that their call may be recorded. If you send us an email, we collect and retain your email address and any PI included in the email.

If you use the live chat functionality through to communicate with one of our live customer service representatives, we may monitor or record our discussions with you for our mutual protection, to confirm our discussions and requested transactions and to enhance our customer service.

Alternatively, you may contact a Strive customer service representative through our Contact Us https://www.strivecapital.ca/#ContactUs section on our Webpage for other options to communicate with us, and again we may collect and retain any PI through this method.

Other Ways We Collect Information:

In general, you can visit our Website without telling us who you are or submitting any PI. However, we collect the IP (Internet Protocol) addresses of visitors to our Website and other information about your visit, such as page requests, browser type, operating system and average time spent on our Website and we use cookies to help us understand your preferences based on previous or current site activity to provide you with improved online services. We may contract with third-party service providers to assist us in better understanding our site visitors and record your browsing habits in order to improve our product and service offerings and customer service. This could include serving Internet based advertising to you directly based on our understanding of your preferences.

Our Website may contain links to other sites that we do not own or operate. Also, links to our Website may be featured on third party websites on which we advertise. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites and social media platforms have separate and independent privacy statements, notices and terms of use, pixels and cookies, which we recommend you read carefully. We do not have any control over such sites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your PI.

We may also offer you the opportunity to engage with us or our content on or through third-party websites (social media). When you engage with us or our content on or through these websites, you may allow us to have access to certain information associated with your account in accordance with your settings on the third-party site (e.g., name, username, email address, profile picture) and we may have access to information about your interactions with our content.

Principle 5 – Limiting Use, Disclosure, and Retention

Principles 2. and 4. above describe the purposes for which we use your PI.

Strive will retain your PI only for the length of time it is required to fulfill the outlined purposes for which you have given your consent for us to use and disclose your PI, and for a reasonable period thereafter in accordance with applicable legal obligations. Information that does not serve a specific purpose or that is no longer required by Strive to fulfil its intended purpose will be anonymized or disposed of in accordance with our record retention policy and in compliance with legal requirements.

We will not disclose your PI without your prior consent, except as otherwise set out herein and as required or permitted by applicable privacy laws. We may disclose your PI in a number of circumstances, namely:

• If you have an application or loan with us that involves another person (e.g., co-borrower) or you add and authorize a third-party to your account, we may share certain details of your PI with that person in connection with your application or loan.
• In the course of Strive fulfilling its normal and regular business activities. For example, disclosure to business partners such as closing agents, financing partners who acquire our loans, mortgage loan insurers, title insurers, lawyers, accountants, auditors, regulatory and governmental authorities, credit rating / consumer reporting agencies and our agents.
• If we sell or securitize your mortgage loan (e.g., as part of the Canada Mortgage Housing Corporation (CMHC) securitization program), we may disclose PI to existing or prospective financing partners or CMHC to facilitate such sale or securitization.
• Where we have affinity or referral programs for certain loan applications for which we are unable to offer lending products, we may refer such loans to other entities offering similar products.
• To credit reporting agencies which may include your mortgage payment performance and to other parties offering credit related products (e.g., creditor life insurance).
• Where we also engage third-party service providers to perform services on our behalf, such as in connection with the servicing and administration of the mortgage loan, hosting our website or online portals, providing customer support services (including research agencies and customer surveys), delivery of mail services, property management, debt collections, borrower identification services, and assisting with processing and sending electronic communications (also known collectively as, “service providers”). Note that the service providers we retain are given only the PI required to perform those services we direct and we do not authorize them to use or disclose PI for any other purpose. We ensure that all service providers operate under executed agreements that hold them to similar standards of confidentiality and privacy by which we are governed. Occasionally these service providers are located outside of Canada. Some of these service providers may be located in Canada or other jurisdictions or countries and as a result your Personal Information may be processed, accessed, or stored outside of Canada. They may disclose information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries in accordance with the applicable law in that jurisdiction or country.

Other Disclosures:

Under certain circumstances, federal and provincial privacy laws permit or require the use or sharing of PI without your knowledge or consent. Strive or our service providers may release information about you without your consent in certain circumstances, namely:

• An investigation by law enforcement and regulatory authorities or self-regulatory organizations.
• If a subpoena, warrant, or court order compels Strive to disclose PI, which may include lawful access by Canadian, U.S. or other foreign governmental authorities, courts or law enforcement agencies.
• Responding to production order requests (e.g., a request from Canada Revenue Agency).
• To protect a debt owed to Strive (e.g., mortgage enforcement proceedings in connection with a delinquent loan).
• To other organizations in the case of investigating a breach of an agreement or contravention of law.
• For the detection, prevention and suppression of fraud and other criminal activity (e.g., illegal grow-operations and money-laundering) and other matters in the public interest.
• For the purposes of meeting legal, regulatory, industry, risk management and security requirements.
• For other purposes permitted or required by applicable laws.

In the event Strive sells, transfers, assigns or otherwise disposes of all or a portion of its business or assets to a third party or undergoes a change of control, Strive may disclose PI without consent for purposes of the potential acquirer’s due diligence and the consummation of such sale, transfer, assignment or disposal. If as part of a prospective or completed corporate transaction, your PI information is required to be transferred or disclosed to the other party or parties we will ensure that the PI information continues to be subject to strict confidentiality and security obligations and that the information is only used for the purposes for which you have provided your consent unless otherwise permitted by law.

When Personal Information is transferred to service providers, we use contractual or other means to ensure that a comparable level of protection is provided.

We may also share aggregated, non-identifiable information with third parties.

Principle 6 – Accuracy

We maintain every effort to ensure your PI is maintained as accurate and complete as necessary for its intended purposes. However, you are responsible for ensuring we have full disclosure of all information and advising us of any changes thereto. Up-to-date complete and accurate information is critical to enable us to make determinations that may affect you. If we are notified of any information that may conflict or is in dispute, we will immediately make a note of this in your customer file. If you become aware of any inaccurate or incomplete PI, please contact us at the contact information listed below.

To prevent fraudulent or unauthorized access to Personal Information, we may take reasonable steps to verify your identity before granting access or making corrections.

Principle 7 – Safeguarding Personal Information

Strive has implemented and continues to implement rigorous safeguards designed to ensure that your PI remains strictly confidential and is protected against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Protection methods include organizational measures such as requiring security clearances and limiting access to a “need-to-know” basis, physical measures such as access cards for employees, visitor ID cards, off-site backups and archiving, and technological measures such as the use of regularly changing passwords on all devices, data encryption, and firewalls which are monitored to ensure any malicious attempts to access them are prevented. We hold our service providers to similar standards.

Strive employees, agents and representatives, including service providers, are informed about the importance of handling PI safely and securely and maintaining the confidentiality of the customer. This is communicated through employment contracts, policies and procedures, and through on-going mandatory privacy training.

Principle 8 – Openness

We are committed to ensuring that our Privacy Policy is written in clearly understandable language and that this is posted online to the public at www.strivecapital.ca.

Principle 9 – Individual Access Rights

We recognize that you have the right to know what information we have about you and to request access to this information. If we are unable for legal or other reasons to provide this to you, we will communicate this to you in writing. Specifically:

• You have the right to access, update, and correct your PI in our custody and control that you can demonstrate is inaccurate or incomplete, subject to certain exceptions prescribed by law.
• You may request access to your PI that we have in our custody or control by sending a written request to us at the contact information set out at the end of this Privacy Policy. You may also update your PI directly on the My Mortgage portal or contact Customer Service. We may request certain PI for the purposes of verifying the identity of the individual seeking access to their PI records.

We may charge you a nominal fee for processing your request and if so, we will give you advance notice of the amount thereof. It may take up to 30 days to conduct the search and respond to your inquiry.

In some cases, we may not provide access to PI about you that is within our possession or control. This may occur if:

• Doing so would reasonably be expected to threaten the life or security of another individual;
• Disclosure would reveal confidential commercial information;
• The PI is protected by solicitor-and-client privilege;
• The information contains PI about other individuals that cannot be severed from your PI;
• The information was collected during the investigation of a legal matter or for purpose related to the detection and prevention of fraud; or
• The information cannot be disclosed for other legal reasons.

If we deny your request for access to your PI, we will advise you in writing of the reason for the refusal.

Principle 10 – Challenging Compliance

You have the right to challenge our compliance with the above principles. If you have any concerns as to how we use your information or the accuracy thereof, please direct your queries to our Chief Privacy Officer at privacy@strivecapital.ca.

Our Chief Privacy Officer will acknowledge receipt of the letter, as well as record the date and the nature of the issue. You will be notified promptly of the relevant steps followed to conduct the investigation and the outcome thereof.

We reserve the right to change our Privacy Policy at any time. We therefore recommend that you review our Privacy Policy every time you interact with us.

For more information about:

• PIPEDA, please visit the web site for the Privacy Commission of Canada at priv.gc.ca

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Québec
K1A 1H3