First National's commitment to privacy

The protection of customer privacy and the confidentiality of customer personal information is an important aspect of First National Financial LP’s (“First National”) business. As a provider of financial products and related services, the collection, use and authorized disclosure of customers’ personal information is fundamental to our day-to-day business operations. We are committed to treating your personal information fairly, with respect and in compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and similar provincial privacy legislation that apply to us. This Privacy Policy describes our privacy practices for our website located at www.firstnational.ca (“Website”), our call centre and other interactions with consumers.

This Privacy Policy does not apply to information about business customers that carry on business as corporations, partnerships or other forms of association, but we protect the confidentiality of such information in accordance with all applicable laws and contractual arrangements.

In this Privacy Policy, the use of the terms “we”, “our” and “us” refers to First National.

What is personal information?

Personal information is information about an identifiable individual. Personal information that we collect may include name, age, gender, home address, home telephone number, unique identification numbers such as government issued identification numbers, financial records, personal references and employment records.

Personal information does not include the name, title, business address, telephone number or email address of an employee of an organization that is used to contact the employee in their business capacity or any information that has been aggregated or anonymized such that an individual’s personal information is non-identifiable.

Accountability to customer

At First National, we take our commitment to safeguarding your personal information very seriously and are accountable for all personal information that is in our possession or under our control. We have appointed a Chief Privacy Officer who is responsible for our privacy compliance program including; analyzing all personal information handling practices at First National, ensuring that the Privacy Policy is up to date, commencing investigations for alleged privacy breaches, responding to customer complaints, handling inquiries and access requests, implementing best practices and updating internal privacy policies and procedures.

First National employees, agents and representatives are informed about the importance of handling personal information safely and securely and maintaining the confidentiality of customer personal information. This is communicated to our employees through employment contracts, policies and procedures and through on-going privacy training.

Why we collect information and how we use your personal information

Whenever we collect personal information, we will explain how we intend to use the information. We limit the information we collect to what we need for those purposes and we use it for the purposes described.

We collect your personal information to establish a relationship with you and to serve your financial needs, including qualifying your mortgage application, determining your eligibility for insurance products, and other related mortgage services and funding and servicing your mortgage loan.

We obtain most of our information about you directly from you or through your interactions with a mortgage broker, as well as from other sources such as, credit reporting agencies, public registries, your employer, personal references and any other organizations with whom you provided your consent to disclose personal information to us. If you have a loan with us that involves another person, we also collect information from that person (i.e. co-borrowers and guarantors). Personal information is collected and used by us for several primary business purposes, such as:

to evaluate your application for financing, particularly with respect to the credit risk being undertaken by reviewing your credit history and transactions (including income sources, assets, liabilities and account history), and to update this information throughout the term of our relationship with you;
to evaluate your financial needs and determine which financial products or related services, whether provided by us or organizations that we conduct business with to help meet your needs;
to verify your identity when you contact us with questions and requests; and to check your name against Canadian and foreign watch and sanctions lists;
to administer our financial and lending programs, including the securitization program sponsored by Canada Mortgage Housing Corporation (“CMHC”);
to offer and administer mortgage life insurance and critical illness products relating to the loan (we collect some personal health information on the application form and provide it to the insurer for processing);
to administer our home warranty program with a third-party provider;
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, fraud and other illegal activities;
to respond to your questions and requests;
to provide you with electronic updates and other information about your application or account;
to provide you with marketing communications with information and offers that may be of interest to you;
to administer our surveys and customer research;
to better understand our customers; and
to comply with legal and regulatory requirements and as otherwise required or permitted by applicable laws.

From time to time we may collect demographic and/or geographic information which assists us in generating trends, statistics and market research for other business purposes.

Monitoring and Recording

(i) Communicating Over the Telephone

First National is committed to superior service to its customers. For our mutual protection and to enhance customer service, customer calls may be monitored or recorded and used for quality assurance, monitoring, security and ongoing training of our employees. In compliance with applicable privacy laws, customers are informed that their call may be recorded. After hearing this message, should you decide to continue with the call, your consent to record the call will be implied. Otherwise, you may contact a First National customer service representative through our Contact Us section on our Webpage for other options to communicate with us. We may also record outbound customer calls placed to our customers for similar purposes.

(ii) Communicating through Live Web Chat

If you use the live chat functionality through My Mortgage 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.

(iii) Communicating through Email

When you send us an email or ask us to reply to you by email, we collect your email address and any other personal information that you have included in the email. We will keep and store your email communications together with our reply, if any, in our records to confirm our discussions and any requested instructions and to assist you in the future.

(iv) Video Monitoring

In the course of operating our business, our office premises are equipped with surveillance cameras. These cameras are placed at points of entry and exit and on business floors with proper notification about video monitoring. Recording of images will capture video-recordings of employees, customers and other visitors and invitees to each office premises. By doing so, this enables the company to protect against theft, vandalism and damage to First National’s premises and property.

Consent

We will obtain your consent to collect, use and disclose your personal information, except as set out under applicable privacy legislation. Consent may be obtained in different ways depending on the situation or interaction with us. Your consent will be obtained prior to using personal information for purposes other than those for which it was originally collected and as set out in this Privacy Policy.

Withdrawing Consent

You may withdraw your consent at any time upon reasonable notice, subject to legal, regulatory or contractual requirements.

If you elect to withdraw your consent, it may affect our ability to continue to provide you with the credit products and services that you have or would like to receive, and which may be of value to you. For example, to obtain a loan, you are required to provide your consent to permit us to obtain and update credit reports and other credit information about you with credit reporting agencies and other organizations that support the credit reporting system.

To withdraw your consent, contact our Chief Privacy Officer at the contact information listed at the end of this Policy.

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. Please note that you may continue to electronically receive transactional and account related communications from us.

Limiting collection of personal information

The personal information about you which we collect will be limited to what is necessary for the purposes identified to you by us. Personal information will be collected by us using fair and lawful means.

How personal information may be shared by us

We will not disclose your personal information without your consent, except as otherwise set out herein and as required or permitted by PIPEDA and other applicable provincial privacy laws.

If you have a loan with us that involves another person (e.g. a co-borrower or guarantor for a loan) or you add and authorize a third party to your account, we may share certain details of your personal information with that person in connection with your loan. We may also share personal information with authorized representatives, such as a legal guardian, power of attorney, lawyer acting on your behalf, your (or co-borrower’s) estate representatives or beneficiaries, where reasonably necessary.

There are some types of disclosure of your personal information which may occasionally occur as part of First National fulfilling its routine obligations and/or conducting its business in the ordinary course. This includes, for example, disclosure to businesses such as investors and funding partners (e.g. financial institutions, pension funds and other similar entities), mortgage loan insurers, title insurers, auditors, regulatory and governmental authorities, credit rating/consumer reporting agencies and our agents.

In the event that we sell or securitize your mortgage loan (e.g. as part of the CMHC securitization program), we may disclose personal information to prospective investors or CMHC to facilitate such sale or securitization.

We may also engage third party service providers (including affiliates) to perform services on our behalf (known collectively as, “service providers”). Such categories of service providers include (but are not limited to):

hosting our website or online portals
providing customer support services (including research agencies, performing analytics and customer surveys)
delivery of mail services
processing and sending electronic communications
property management
debt collections
borrower identification services
data processing
technological services and support (including cloud and storage providers)

The service providers we retain are given only the personal information needed to perform those services we direct and we do not authorize them to use or disclose personal information for any other purpose. As well, service providers are subject to their own legal compliance requirements and the laws of their jurisdiction. Some service providers and their processing servers may be located outside of Canada (such as North America, South America and in Asia) and may be required to disclose information to courts, government authorities, regulators or law enforcement in accordance with applicable laws of that country. For more information on the manner in which our service providers treat your personal information, please contact our Chief Privacy Officer as set out at the end of this Privacy Policy.

First National uses contracts and other agreements with service providers, holding them to similar standards of confidentiality and privacy by which we are governed.

Other Disclosures

Under certain circumstances, federal and provincial privacy laws permit or require the use or sharing of personal information without a customer’s knowledge or consent. We or our service providers may release information about you without your consent in certain circumstances, including the following:

an investigation by law enforcement and regulatory authorities or self-regulatory organizations
if a warrant, court order or other instrument compels First National to disclose personal information, 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. from Canada Customs and Canada Revenue Agency)
the protection of First National assets (e.g. mortgage enforcement proceedings in connection with a delinquent loan) or where necessary for the establishment, exercise or defence of legal claims
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
the protection of First National’s employees, customers and others
in situations otherwise permitted or required by applicable Canadian, U.S. or other law

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

Over time, First National may sell all or parts of its business or assets, acquire new businesses, undergo a change in corporate control or enter into other types of corporate transactions with third parties. As part of a prospective or completed corporate transaction, your personal information may or may not be required to be transferred or disclosed to the other party or parties. Where it is necessary for us to disclose or transfer your personal information to either a purchaser or another party to a transaction and their professional advisors, we will ensure that the personal 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.

Retention of information

We will retain your personal information for the time it is required to meet the purposes set out above and for a reasonable length of time thereafter or to otherwise meet legal or regulatory requirements (e.g. for tax purposes), even if you cease to be a customer. Once your personal information is no longer required for such purposes, it will be destroyed or made anonymous.

Accuracy of information

We make all reasonable efforts to keep your information up-to-date and we endeavor to base our decisions on accurate and timely information when we make a determination that may impact you. We rely on you to disclose all material information to us and to inform us of out-of-date or incomplete information (for example, a name change or change in telephone number). If you discover any inaccurate information, you can update it on My Mortgage (residential customers) or contact us by phone or email, and we will make the corrections and ensure this change of information is conveyed to third parties to whom we may have provided the information, such as a credit reporting agency. We want to ensure that our service to you is not affected by incomplete or inaccurate information.

For any information that may conflict or is in dispute, we will make a note of this in your customer file.

Safeguarding your information

First National secures and protects personal information in our custody and control, whether in electronic or paper based format, with safeguards and security measures appropriate to the sensitivity of the personal information, in an effort to protect against the theft, loss and unauthorized access, disclosure, copying or use of personal information. These safeguards include physical security controls (locked filing cabinets and restricted access to offices through security pass cards), technological security controls (passwords to computer terminals, personal identification numbers, encryption and password protection, audit trails and alerts, access levels and timed out computer terminals) and organization controls (such as policies and procedures and annual audit tests).

We review privacy and security procedures regularly to ensure that they are being properly administered and that they remain effective and appropriate to the sensitivity of the personal information. We also ensure that there is a comparable level of protection for information that is processed for us by our service providers.

Openness

First National has prepared this Privacy Policy to keep you informed. It is made available to the public in paper format by submitting a request at the address set out at the end of this Privacy Policy, and in electronic format available on our Website.

Website information

In general, you can visit our Website without telling us who you are or submitting any personal information. 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. We use this information to help us understand our Website activity, and to monitor and improve our Website.

A note about the use of Web tools such as Cookies

Cookies are small files that a website or its service provider transfers to a computer’s hard drive through your browser, enabling the site or service provider's system to recognize your browser (e.g. Google Chrome, Internet Explorer, Firefox and Safari) and capture and remember certain information, such as your browser type and address of the website from which you arrived from.

We use cookies to help us understand your preferences based on previous or current site activity and it allows us to provide you with improved online services. We also use cookies to temporarily store language and filter preferences on our site and web portals (such as My Mortgage). This helps us understand visitor traffic to our sites, site interaction in order to offer a user-friendly experience and to recognize you when you return to our sites.

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.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies by changing the settings in your browser. We note that if you turn cookies off, you will not have access to certain features on our sites that make your online experience more efficient and some of our services may not function properly.

Our Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our Website and provides us with website analytics. These tracer tags are used to help us optimize and tailor our Website for you and other future visitors to our Website.

Interest-Based Advertising

We work with third parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website and other websites in order to provide you with tailored advertisements across the Internet. This is a common marketing practice referred to as interest-based or online behavioural advertising. These companies may collect information about your activity across your different devices on our Website and third-party websites (such as web pages you visit and your interaction with our advertising) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate our online advertising campaigns.

Opting-out of Interest-Based Advertising: For more information about interest-based advertising on your desktop or mobile browser and to understand your options, including how you can opt-out of receiving interest-based ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada (DAAC) Self-Regulatory Program for Online Interest-Based Advertising, please visit the DAAC website at http://youradchoices.ca/choices.

Important Notes About your Opt-Out:

If you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us across the Internet, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.

Interest-based advertising opt-outs work by saving cookies in your browser that tell the various ad partners that you have opted-out. Your choice will only apply to the web browser from which you opt-out. You must opt-out from each web browser from which you do not want interest-based advertising (and this may involve different devices, if you use more than one). If you delete or clear your browser’s cookies, you will need to opt-out again.

Analytics

We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies.

For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

You can also obtain additional information on Google Analytics’ data privacy and security at the following links:

Social Media

We may offer you the opportunity to engage with us or our content on or through third-party websites (such as LinkedIn or YouTube). 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.

Third Party Links

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 personal information.

Access to your information

You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access to your personal information and update and correct inaccuracies in the personal information 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 personal information directly on the My Mortgage portal or contacting Customer Service. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information 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 personal information 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 personal information is protected by solicitor-and-client privilege;
the information contains personal information about other individuals;
the information was collected during the investigation of a legal matter or for purposed 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 personal information, we will advise you in writing of the reason for the refusal.

Challenging compliance – how First National respects and responds to your privacy concerns

You may contact us with any questions or concerns you might have about your privacy or about this Privacy Policy. You should direct these questions to First National's Privacy Office at the telephone, e-mail address or mailing address listed below. The Chief Privacy Officer may from time to time, designate one or more individuals to act on her/his behalf.

Please be sure to include your name, address, mortgage number (if applicable), preferred method of communication, the nature of your question or complaint and relevant details, including past communications with us, if any. If you have a complaint and it is justified, we will take the steps necessary to resolve the issue.

First National Financial LP
16 York Street, Suite 1900
Toronto, Ontario M5J 0E6

Attention: Hilda W. Wong, Chief Privacy Officer

Telephone No: 416-593-1100
E-mail: privacy@firstnational.ca

If the Chief Privacy Officer does not resolve the issue to the customer’s satisfaction, the customer may contact the Privacy Commissioner of Canada, or other applicable privacy commissioners:

We may amend this Privacy Policy from time to time to take into account any changes in applicable privacy laws or other regulatory issues that are relevant. If we make any changes to our Privacy Policy, we will post the updated version on our Website. A pamphlet is available upon written request.

We encourage you to review this Privacy Policy whenever you communicate with us to stay informed about our information handling practices.

Last update: September 2023