Privacy Policy

1. Who We Are

Lijo Abraham is a Mortgage Agent Level 1, licensed by the Financial Services Regulatory Authority of Ontario (FSRA) under licence #M26000806. All mortgage brokering activity is carried out on behalf of and under the supervision of Pegasus Mortgage Lending Center Inc. (the "Brokerage"), FSRA Brokerage Licence #11479. Under the Mortgage Brokerages, Lenders and Administrators Act, 2006 (Ontario) (the "MBLAA") and O. Reg. 188/08, the Brokerage is the entity responsible for compliance with privacy and record-keeping obligations relating to your mortgage file. This Policy describes how your personal information is handled by Lijo Abraham and the Brokerage in connection with this portal and any related mortgage services.

2. Legal Framework

We handle personal information in accordance with:

• The Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c. 5;
• Canada's Anti-Spam Legislation (CASL), S.C. 2010, c. 23;
• The MBLAA and its regulations, including O. Reg. 188/08 (Mortgage Brokerages: Standards of Practice), O. Reg. 187/08 (Mortgage Brokers and Agents: Standards of Practice) and O. Reg. 193/08 (Reporting Requirements for Licensees);
• The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC obligations applicable to mortgage brokering; and
• FSRA guidance, rules and licensing conditions in force from time to time.

3. Information We Collect

We collect personal information that is reasonably necessary to assess your mortgage needs, recommend a suitable product, submit applications to lenders, and meet our regulatory obligations. This typically includes:

• Identification information required by FINTRAC (legal name, date of birth, government-issued ID details, occupation);
• Contact information (address, email, telephone);
• Financial information (income, assets, liabilities, credit history, banking information, source of down payment);
• Employment information;
• Property information (address, value, MLS data, purchase agreement);
• Information about co-applicants and guarantors, where you have authority to provide it;
• Account credentials for this portal (passwords are stored only as one-way cryptographic hashes); and
• Technical information such as IP address, browser type and session activity for security and fraud prevention.

We collect information directly from you, and — with your consent — from credit reporting agencies (Equifax and TransUnion), employers, financial institutions and other third parties needed to verify your application.

4. Purposes & Consent

We use your personal information only for purposes you would reasonably expect:

• Assessing the suitability of a mortgage product for your circumstances;
• Submitting your application to lenders, mortgage default insurers (e.g. CMHC, Sagen, Canada Guaranty), appraisers, lawyers and other parties required to complete the transaction;
• Pulling credit reports and verifying employment, income and identity (with your express consent);
• Communicating with you about your file, renewals and refinancing opportunities you have asked us to track;
• Fraud prevention, account security and account administration;
• Meeting legal, regulatory, tax, audit and record-retention obligations (including FSRA examinations and FINTRAC reporting); and
• Responding to lawful requests by public authorities.

We obtain express consent for credit checks and for sharing your file with lenders. You may withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice; if you withdraw consent, we may not be able to continue providing mortgage brokering services to you.

5. Disclosure to Lenders & Service Providers

We do not sell your personal information. With your consent we disclose information to:

• Lenders and mortgage default insurers reviewing your application;
• Pegasus Mortgage Lending Center Inc., its Principal Broker and compliance staff, for supervision, audit and record-keeping;
• Credit reporting agencies, appraisers, lawyers, notaries and title insurers required to complete a transaction;
• Service providers that host this portal, transmit documents, perform identity verification, send email or store records on our behalf, under written confidentiality and security obligations;
• FSRA, FINTRAC, the Canada Revenue Agency, courts and other authorities where required or permitted by law.

Some service providers may store or process information outside Ontario or Canada; in those cases the information may be subject to the laws of the foreign jurisdiction, including lawful access by its authorities.

6. Retention

Mortgage brokerage records, including documents and electronic records relating to transactions and to your file, are retained by the Brokerage for a minimum of six (6) years from the date the relevant document was created or the transaction concluded, as required by O. Reg. 188/08. Records may be kept longer where required by FINTRAC, tax law or to defend against legal claims. After the retention period expires we securely destroy or de-identify the information.

7. Safeguards

We use administrative, physical and technical safeguards proportionate to the sensitivity of the information, including TLS encryption in transit, access controls, password hashing, audit logging, role-based access within the Brokerage, and staff training on confidentiality and conflict-of-interest obligations under the MBLAA. No method of transmission or storage is perfectly secure; in the event of a privacy breach posing a real risk of significant harm we will notify affected individuals and the Office of the Privacy Commissioner of Canada in accordance with PIPEDA's breach-reporting requirements.

8. CASL & Electronic Communications

We send commercial electronic messages only with your express or implied consent permitted under CASL. Every commercial message identifies the sender, provides our contact information, and includes a working unsubscribe mechanism that takes effect within ten (10) business days. Service messages directly related to your active mortgage file (for example, document requests or status updates) are transactional and may be sent regardless of marketing preferences.

9. Your Rights Under PIPEDA

• Access the personal information we hold about you;
• Request correction of inaccurate or incomplete information;
• Withdraw consent (subject to legal or contractual restrictions);
• Make a complaint to the Brokerage's Privacy Officer, and, if unresolved, to the Office of the Privacy Commissioner of Canada (priv.gc.ca).

We will respond to verified access requests within thirty (30) days, as required by PIPEDA.

10. Cookies & Analytics

This portal uses strictly necessary cookies and similar technologies for session management, security and remembering your preferences. We do not use advertising cookies. Aggregate, non-identifying analytics may be collected to monitor performance and detect abuse.

11. Changes to this Policy

We may update this Policy from time to time to reflect changes in law, regulation or our practices. The "Last updated" date above will indicate when the Policy was most recently revised. Material changes will be brought to your attention through the portal or by email.

12. Contact — Privacy Officer

You may verify our licences on FSRA's public registry at fsrao.ca.