Privacy Policy

At InstaFund Financial (Commercial) (“InstaFund”), we are dedicated to protecting your privacy and safeguarding the personal, business, and financial information entrusted to us. This Privacy Policy documents our on-going commitment to you and has been developed in compliance with the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and corresponding provincial privacy acts, as applicable (collectively “Privacy Laws”).

Introduction

InstaFund is an active mortgage brokerage company duly licensed and registered as a mortgage broker in compliance with provincial laws. All InstaFund employees conducting mortgage broker services, as defined by provincial laws, are duly licensed and registered to conduct such mortgage broker services in compliance with provincial laws. In the course of providing mortgage broker services, InstaFund may collect certain personal information about you with your consent.

Personal
Information

“Personal Information” means any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form such as, but not limited to, your age, name, ID numbers, income, home address, credit records or other financial information, opinions, evaluations and comments. Personal Information does not include your name, business contact information, or other publicly available printed and electronic information.

In the course of providing mortgage broker services, InstaFund may share your Personal Information with financial institutions, private lenders, credit reporting agencies, affiliates or others parties directly involved in the mortgage process.

Privacy Principles

Based on Privacy Laws, we have tailored the following 9 privacy principles that all InstaFund employees have adopted to ensure your privacy rights are protected.

1. Accountability
2. Identifying Purpose
3. Consent
4. Limiting Collection
5. Limiting Use, Disclosure and Retention

Principle 1 —
Accountability

InstaFund is accountable for the protection of your Personal Information under its custody and control. While senior management is ultimately accountable for the protection of Personal Information, the day-to-day monitoring for compliance may be delegated to other staff.

InstaFund’s Privacy Officer bears the overall responsibility for the protection of Personal Information and compliance with this Privacy Policy and Privacy Laws. Any inquiries, complaints or questions regarding this Privacy Policy should be directed in writing to the InstaFund Privacy Officer.

Principle 2 —
Identitying Purposes

InstaFund will communicate the purposes for which your Personal Information is being collected, either orally or in writing. We do this explicitly or by implication where the purpose of using such Personal Information is reasonably apparent to you by virtue of its nature or the context in which it is being collected.

Principle 3 —
Consent

InstaFund will obtain your consent before or when it collects, uses or discloses your Personal Information. The method of obtaining consent will be appropriate to the type of Personal Information being collected, used or disclosed.

Consent can be express, implied, or given through an authorized representative such as a lawyer, agent or broker.

In some circumstances, as permitted by Privacy Laws, we will collect, use and disclose your Personal Information without your consent, including situations of urgency when it is impractical to obtain your consent, when InstaFund or its affiliates need to collect monies or in connection with an investigation or proceeding by InstaFund or its affiliates or a law enforcement agency.

Consent may be withdrawn at any time, subject to legal or contractual restrictions, provided that reasonable notice or withdrawal of consent is given to InstaFund.

Principle 4 —
Limiting Collection

Personal Information collected by InstaFund will be limited to those details necessary for the purpose for which it was collected. Personal Information will be collected only by reasonable and lawful means.

Principle 5 —
Limiting Use, 
Disclosure and
Retention

Personal Information is only to be used or disclosed for purposes for which it was collected unless permitted by Privacy Laws. InstaFund does not sell or rent Personal Information to any organization or person for any reason.

Personal Information may only be retained for the amount of time needed to fulfill the purpose for which it was collected or as required by applicable laws. InstaFund takes due care when destroying Personal Information to prevent unauthorized access to the information.

Principle 6 —
Accuracy

InstaFund will keep Personal Information as accurate, complete and current as necessary to fulfill the purpose for which it was collected. You can assist us by updating your Personal Information where it is found to be inaccurate or incomplete.

Principle 7 —
Safeguarding
Personal
Information

Personal Information is safeguarded using measures appropriate to the sensitivity of the information and in keeping with generally accepted industry standards, including:

• Physical security measures such as restricted access facilities and locked filing cabinets
• Shredding of documents containing Personal Information
• Technological security measures such as password, encryption and firewall protection
• Organizational processes such as limiting access to your Personal Information on a “need-to-know” basis

InstaFund is committed to ensuring that the appropriate security measures are employed in the transfer of sensitive information. However, confidentiality and security are not assured when information is transmitted through e-mail, internet or wireless communication on unencrypted systems. InstaFund is not responsible for any loss or damage suffered as a result of a breach of security and/or confidentiality when you transmit information to InstaFund by these methods or when InstaFund transmits such information by these methods at your request.

Principle 8 —
Openness &
Access

InstaFund is open about the practices it uses to protect Personal Information and information about these practices is available either electronically or in written format. To ensure the integrity of our security and business methods, InstaFund may refuse to disclose certain information.

Upon your request, InstaFund will make the following information available to you within a reasonable period of time:

• The title and address of the person accountable for the policies and procedures and to whom complaints or inquiries can be forwarded;
• A description of the type of Personal Information held by InstaFund, including a general account of its use;
• An explanation of what Personal Information is made available to related organizations;
• Reasonable access to your Personal Information so you can review and verify its accuracy and completeness and
request changes to the information. InstaFund reserves the right to decline to make a requested correction but will
append a notation to the record of your requested alternative information;
• Updates to your Personal Information.

Subject to applicable exceptions under Privacy Laws, such as where:

• Your request would divulge confidential competitive business information of InstaFund;
• The information is not readily retrievable and the burden or cost of providing access is disproportionate to the nature
of the request;
• Access could interfere with or prejudice an investigation or proceeding by InstaFund or its affiliates or law
enforcement agencies.

Principle 9 —
Recourse

You may direct any complaints, concerns or questions regarding this Privacy Policy in writing to InstaFund’s Privacy Officer as follows:

InstaFund Financial (Commercial)
ATTN: Privacy Officer
Suite 620 – 1040 West Georgia Street
Vancouver, B.C, V6E 4H1

InstaFund and/or its Privacy Officer will acknowledge, record and investigate each privacy complaint it receives within a reasonable period of time.

Please note that this Privacy Policy is now deemed to be our current Privacy Policy effective January 1st, 2011 and remains in effect until amended. InstaFund reserves the right to amend this Privacy Policy or alter its privacy principles at its sole discretion without notice to you. Any alterations to this Privacy Policy or our privacy principles will be posted on our web site in a timely manner.