Privacy Policy

The privacy of our investors is very important to us. This Privacy Policy sets out the information practices for Frontenac Mortgage Investment Corporation’s shareholders, including what types of personal and business information is collected, how the information is used, and with whom the information is sharedin the course of business, and through digital platforms we use to deliver services. We are committed to protecting your privacy and maintaining the confidentiality of your information.It is essential for the long-term success of our business and to protect our clients’ interests.We may update it from time to time to better reflect changes in our services, collection, use or disclosure of your personal information and to account for changes in privacy laws. This Privacy Policy was last modified in March 2025.

Frontenac Mortgage Investment Corporation complies with the requirements of Part 1 and Schedule 1 of the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) and all applicable provincial personal information laws. Below is an overview of the privacy principles set out in Schedule 1 of PIPEDA. For more information, you can visit the official website of the Privacy Commission of Canada at https://www.priv.gc.ca/ .

 

Your privacy is important to us. We may collect the information you submit via this website for the purpose of keeping you up to date on our current projects and news releases. We and/or our agents will use this data solely to comply with any request for information, submission of relevant application, or in a manner otherwise disclosed or authorized by you. We will not sell, disclose or otherwise transfer your personal information submitted to us to any third party with the exception of disclosing information to the extent that we are required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend our legal rights. All personal information submitted is stored on a secure server with limited access.

We have strict policies and procedures governing how we deal with your personal information. Every one of our employees is responsible for respecting and protecting the personal information to which the employee has access to.

To better ensure that we live up to the goals and commitments expressed in this policy, we have appointed a Privacy Officer to oversee it. If you’d like to know more about this policy or have questions about how we manage your personal information, please contact our Privacy Officer, Amber Kehoe, at [email protected] or 877-279-3061.

 

You can also get in touch with our Privacy Officer at:

Frontenac Mortgage Investment Corporation

14216 Road 38

Sharbot Lake, ON K0H2P0

Attn: Privacy Officer

 

Please reach out to us if you have any comments, questions or concerns about this policy or your personal information.

If you have completed the above process and we have been unable to resolve your concern, you may file a complaint with the Privacy Commissioner of Canada or the appropriate provincial privacy officer. The Privacy Commissioner of Canada may be contacted at Place de Ville 112 Kent St., 34d Floor Ottawa, ON, K1A 1H3 Toll free at +1 800 282 1376 https://www.priv.gc.ca.

Definitions you need to know

Dealer means an individual or entity acting or representing you in connection with your investments as your investment advisor, broker, or dealer, or on behalf of your investment advisor, broker, or dealer. We are entitled to accept and act on any notice, authorization, or other communication that we believe in good faith to be given by you or your Dealer on your behalf. We are under no obligation to verify that your Dealer is properly authorized to act as your agent or is otherwise authorized to act on your behalf.

Service means any brokerage or financial product or service offered by us.

You and your means each person, whether an individual, corporation, your Dealer or trust, who has made and investment, or provided instructions to us, including any co-applicants, guarantors or personal or corporate representatives such as directors.

Canadian Investment Regulatory Authority (CIRO) refers to the self-regulatory organization (formerly IIROC and MFDA) that regulates investment dealers and mutual fund dealers, the exchanges and other regulated marketplaces and the Canadian Investor Protection Fund.

What personal information do we collect?

The term “personal information” refers to any information related to an identifiable individual, such as yourself, your spouse, or your children, except for business contact information. An “identifiable individual” is someone who can be identified, either directly or indirectly, through information such as name, home address, personal telephone number, social insurance number, financial transactions, online behaviors, as well as factors specific to the individual such as gender or date of birth.

The personal information about you which we collect will be limited to that which is necessary for the purposes we identified to you. Information will be collected by us only by fair and lawful means. We will not use or disclose your personal information for purposes other than those identified to you at the time or before your consent was given. We will seek your further consent before using the information for purposes beyond the scope of your original consent.
There are some necessary types of disclosure of your personal information which occasionally occur as part of Frontenac Mortgage Investment Corporation fulfilling its routine obligations and conducting its business in the ordinary course. This includes, for example, disclosure to third party lenders, rating agencies, consumer reporting agencies, partners, consultants, and suppliers (also known collectively as “service providers”). We will retain your information only for the time it is required for the identified purposes and for a reasonable length of time thereafter in case we need to meet any potential obligations or legal or government requirements. Once your personal information is no longer required, it will be destroyed or made anonymous.

We collect the following types of client information about you for the purposes set out above:

  • Information which enables us to identify and communicate with you including name, address, phone number, e-mail address, and language preference
  • Information which enables us to offer you services that better meet your needs including demographic information such as birth date, education level, occupation, marital and family status, purchase preferences and interests.

Why do we collect your personal information?

We collect and use personal information for several reasons. Either before or at the time we collect personal information, we will explain how we intend to use it and limit collection and use to those purposes. We will ask for your further consent before it can be used for any other purpose. Additional information may be obtained via credit reporting agencies and other third party sources.
Personal information is collected to establish a relationship and to serve your financial needs. It is used:
• to verify your identity;
• to determine the suitability of our products and services;
• to understand your financial needs and determine which financial products or related services may be of use to you and help meet your needs, and to offer those to you either ourselves or organizations with which we have strategic alliances;
• to administer our financial and lending programs and provide ongoing service including dealing with your mortgage agent or broker; and
• to comply with legal requirements and regulations.

 

How do we collect your information?

We collect your personal or business information directly from you or through your financial advisor and/or dealer in order to provide you with Services, to meet legal and regulatory requirements and for any other purposes to which you consent. Your information may be collected from a variety of sources, including:

  • Subscription forms, applications, questionnaires or other forms that you submit to us or agreements and contracts that you enter into with us;
  • Your transactions with us;
  • Meetings and telephone conversations with you;
  • E-mail communications with us; and
  • Our websites.

How do we use your information?

We use your personal information for a variety of purposes. It is used to help us provide you with investment management services and to satisfy information requests from regulators and other organizations or individuals who are legally entitled to make such requests. We use your information to: (a) communicate with you; (b) manage our risks and operations; (c) meet our regulatory and legal requirements; and (d) provide the other services you request from us. We also use it to determine whether you might benefit from, or be interested in discussing new services, products, and to evaluate and improve our digital platforms. Finally, we use your personal information to comply with legal obligations.

We collect, use and disclose your SIN, social security number or other government-issued personal or business identification number for income tax reporting purposes, as required by law. In addition, we may ask you for your SIN to confirm your identity. This allows us to keep your personal information separate from that of other customers, particularly those with similar names, and helps maintain the integrity and accuracy of your personal information. You may refuse to consent to its use or disclosure for purposes other than as required by law.

How do we obtain your consent?

We rely on your actions as indications of your consent to our collection, use and disclosure of your personal information. For example, by signing a subscription form or an application form, voluntarily providing your information to us directly or through your financial advisor or dealer and continuing to do business with us, you are consenting to the collection, use and disclosure of your personal information for the purposes identified in this Privacy Policy. Your consent is required before we may collect, use or disclose your personal information, except in special circumstances, such as legal and security situations. To withdraw your consent, you should contact our Privacy Officer at the address or telephone number listed below.

With certain exceptions as outlined below, we will obtain your consent to collect, use or disclose personal information. This consent will allow us to check your employment, obtain a credit report and exchange information with credit reporting agencies and share your information with our affiliates. In most cases, we will seek your consent to use your personal information. Your consent may be given in writing, verbally or by electronic means. We may rely upon implied consent where permitted by law including where the following situations occur:

  • Where a customer relationship already exists;
  • Where express consent has been previously been given for the same or similar use of the personal information;
  • Where the intended use is reasonably obvious from the context in which it is obtained and you provide the information voluntarily.

The following are exceptions where we may collect, use or disclose personal information without consent and for which you may not withdraw consent:

  • If we use an outside supplier to do work for us as outlined above;
  • If we are compelled to release information by a court or other legal or regulatory authority or permitted to do so by law;
  • To protect our interests, such as collecting overdue payments, realizing on security pledged for a loan, or to detect or prevent fraud;
  • To periodically update your personal information with credit reporting agencies as long as you have a loan with us and for a period of time following payment, in order to maintain the integrity of the credit reporting system;
  • Where we need to exchange or disclose customer information to syndicate or assign your mortgage or loan, or as part of the sale or merger of our business.

Where you are permitted to withdraw your consent, and you do withdraw your consent, (if, for example you choose not to receive direct marketing), we will do our best to make sure that our files are updated as quickly as possible. You must give us reasonable notice of your withdrawal of consent in writing. If you withdraw your consent, we will inform you of the implications of such withdrawal. To withdraw your consent, simply contact us and advise us of what personal information you no longer wish us to use. Withdrawal of your consent may result in us being unable to continue to offer you our products or services.

Who do we share your information with?

We do not provide directly all the services related to your relationship with us. As such, we may transfer your personal information, when necessary, to our third party service providers and to our agents in connection with the Services, however, please note that these third party service providers and agents will not share this information with others. Such information is only used for the purposes identified above. We may use third party service providers or agents such as:

  • Your financial advisor or dealer;
  • Other financial service providers such as investment dealers, custodians, prime brokers, banks and others used to finance or facilitate transactions or operations on your behalf;
  • Registrar and transfer agents, portfolio managers, brokerage firms and similar service providers; and
  • Other service providers such as accounting, legal or tax preparation services.

Our service providers and our agents process or handle your information on our behalf and assist us with various services such as printing, imaging, document storage and shredding, mail distribution and marketing. Some of these third parties may be located outside of Canada. As a result, your information may be accessible to regulatory authorities in accordance with the laws of these jurisdictions. When information is provided to our service providers and to our agents, we will require them to protect the information in a manner that is consistent our privacy policies and practices.

We may also be required by law to disclose information to government regulatory authorities. For example, we may be required to report your income to taxation authorities. We may also be required to disclose your personal and business information to CIRO. CIRO collects, maintains, and discloses such information for regulatory purposes, including trading surveillance, audits, investigations, maintenance of regulatory databases and enforcement proceedings. CIRO may, in turn, disclose such information when reporting to securities regulators or when sharing information with law enforcement agencies.

We do not sell, lease, barter or otherwise deal with your personal information with third parties. Frontenac Mortgage Investment Corporation may be involved in the sale, transfer or reorganization of some or all of its business at some time in the future. As part of that sale, transfer or reorganization, we may disclose your personal and business information to the acquiring organization, however, we will require the acquiring organization to agree to protect the privacy of your personal and business information in a manner that is consistent with this Privacy Policy.

How long do we keep your information?

We only keep your personal information as long as it is necessary to do so. The length of time we keep your information depends on the nature of the information as well as legal and regulatory requirements.

Personal information is retained as long as required to fulfill these purposes. We have established retention policies and procedures to ensure that when the retention period expires, your personal information will be removed from our systems and destroyed in a secure manner.

 

How do we protect your personal information?

 

To keep your personal information safe, we use industry-standard, client-conscious controls, processes, software, systems, training programs and physical safeguards, which we select based on the sensitivity of the particular items of personal information each method secures. We also test our security plans regularly, and use systems that automatically update and improve themselves as new threats arise.

 

All employees are familiar with the procedures required to safeguard client information, and they are required to always maintain the confidentiality of such information, failing to do so may result in disciplinary measures. Protecting your information is an essential part of our job. To protect your information all employees sign a confidentiality agreement when hired. Additionally, all employees annually certify that they have complied with our privacy policy.

 

No organization, including Frontenac Mortgage Investment Corporation, can guarantee the ongoing security, integrity or secrecy of your personal information. Even organizations that employ teams specialized in data and information security will from time to time suffer security incidents. Therefore, while we wish we could do so, Frontenac Mortgage Investment Corporationcannot promise that we will be able to prevent unauthorized disclosure, modification or destruction of personal information you provide us.

 

What can you do to help protect your personal information?

 

The most important thing you can do to keep your personal information safe is to protect, and keep secret, your usernames and passwords. The second most important thing you can do is to restrict communication of highly-sensitive personal information to in-person meetings, or through secure, encrypted communication services – not email.

 

What happens if we find out your personal information has been lost or stolen?

 

If we uncover a privacy incident, or reasonably suspect a privacy breach involving your personal information, we will investigate and evaluate its implications promptly, and immediately take the measures necessary to reduce the risk of harm. If a privacy incident creates a real risk of significant harm to you or any other individual, we will activate our privacy breach notification protocol – we have processes, procedures and service providers in place so that we can attempt to minimize the scope or magnitude of harm in a timely manner, and comply with our notification obligations under the law.

 

How can you see what personal information we have about you?

 

If you would like to access your personal information, please contact our Privacy Officer in writing. Upon such request, we will give you access to the information we retain about you. We generally require proof of identity before we release any personal information to you. We will then provide you with the personal information we have about you, unless we are required by law to refrain from doing so, or believe we have a right to refrain from doing so, and choose to exercise such right. You may verify the accuracy and completeness of the personal information we have about you, and may also ask us to amend it.

How do you withdraw your consent?

Subject to legal, regulatory and contractual requirements, you may refuse to consent to our collection, use or disclosure of your personal or business information, or you may withdraw your consent to our further collection, use or disclosure of your information at any time in the future by giving us reasonable notice. Depending on the circumstances, however, withdrawal of your consent may impact our ability to provide you, or continue to provide you, with some Services or information that may be of value to you. We will inform you of the implications of your withdrawal of consent for the continued promises of service to you. We will act on your instructions as quickly as possible but there may be certain uses of your information that we may not be able to stop immediately.

How do we safeguard personal information?

We carefully safeguard your personal information and, to that end, restrict access to personal information about you to those employees and other persons who need to know the information to enable us to provide Services to you. Our employees are responsible for ensuring the confidentiality of all personal information they may access. Annually, each of our employees are required to sign a code of conduct, which contains policies on the protection of personal information.

We will protect your information, whether in electronic or paper-based format, with strict safeguards and security measures, to protect it from unauthorized access, disclosure, or misuse.

What are the risks?

Although we take steps to safeguard the information under our control, “perfect security” does not exist. In particular, we cannot guarantee the security of the information communicated to us via email. It is possible that third parties may unlawfully intercept or access such information.

Who do you contact if you have any questions, concerns or complaints?

If you have any questions about our privacy policies and practices and how they relate to you or if you wish to raise a complaint on how we handled your personal information, you can contact our Chief Privacy Officer who will then investigate the matter. You can contact our Chief Privacy Officer by telephone at 1-877-279-3061, by e-mail at [email protected],by mail to Frontenac Mortgage Investment Corporation, 14216 Road 28, Sharbot Lake, ON K0H 2P0 Attention: Chief Privacy Officer.

If you want to escalate, you can contact The Office of the Privacy Commissioner of Canada. Complaints to the Office of the Privacy Commissioner must be submitted in writing to 112 Kent Street, Place de Ville, Tower B, 3rd Floor, Ottawa, Ontario K1A 1H3 Attention: The Privacy Commissioner of Canada.

Use of web tools

We or our service providers may use various tracking tools, such as Cookies, Pixel Tags and Web Beacons, on our website and in our emails and advertisements. Pixel Tags, Web Beacons and similar technologies are tracking tools that may be used on our website and in our emails that monitor user activity. They help us capture user activity for analysis to better understand use and effectiveness of the website and emails, enhance user experience and provide additional security controls.While the data collected by cookies doesn’t directly identify you, we may use it with other information, including personal information, as needed to meet these objectives.

Refusing cookies

You can limit the collection of your information by disabling cookies on your browser. You may also be able to modify your browser settings to require your permission each time a website attempts to set a cookie. However, our websites (and many other websites) rely on cookies to enable certain functionality. If you choose to disable cookies, some of the services available on our websites may not work properly. We also use log file information for functionality, security, account management and usage analytics. Most browsers automatically collect information like your IP address, device type, screen resolution, operating system version, internet browser type and version, and time of visit or log-in and store it in log files.

A note about cookies

A “cookie” is a small data file stored on your system that allows it to be identified as you move from page to page on the Internet by associating it with an alphanumeric code. Our digital platforms use cookies as a consequence of certain features, and in order to analyze user behaviour and improve our offerings.

Some cookies are necessary to enable you to move around our website and use its features. These cookies enhance the convenience and use of the website. If you disable required cookies, some features of the website will be affected or may not work at all.

Other cookies are helpful to allow us to understand how people use our digital platforms.

Use of third parties

Our website may contain links to third party websites. We are not responsible for the practices of those third-party websites. Where you access other websites from our website using the links provided, the operators of these websites may use cookies in accordance with their own policies, which may differ from ours. You should read their privacy and cookie policies carefully before you provide any personal information to them.

Although the Website may link to other resources (such as websites, mobile applications, etc.), we are not, directly or indirectly, implying any approval, association, sponsorship, endorsement, or affiliation with any linked resource, unless specifically stated herein. We are not responsible for examining or evaluating, and we do not warrant the offerings of, any businesses or individuals or the content of their resources. We do not assume any responsibility or liability for the actions, products, services, and content of any other third parties. You should carefully review the legal statements and other conditions of use of any resource which you access through a link on the Website and Services. Your linking to any other off-site resources is at your own risk.

We may use third party providers to help collect and compile information like the number of visitors to our websites, where visitors have come to our websites from and the pages they visit. Our third-party providers may also use cookies to deliver advertisements that are more relevant to you and your interests and to help measure the effectiveness of an advertising campaign. Third party providers will not have access to your name or other identifying information.

Our site uses automated, third party tools such as Google Analytics to collect and analyze information about use of the sites and engagement with our content and communications, and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources, such as links you followed to access our website.

You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/.

Frontenac Mortgage Investment Corporationuses Google Analytics to better understand the nature of the traffic on our website, including how long your site visit was, the pages you visited, and whether you have visited our site previously. We use the information from Google Analytics for user experience improvements and for tailoring content to improve the overall utility of our website to its visitors.

To learn more about Google Analytics, or to opt out, visithttp://tools.google.com/dlpage/gaoptout.

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 Facebook). 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.

Internet-based advertising

Interest-based advertising allows us to deliver advertisements that are more relevant to you and your interests. It works by showing you advertisements that are based on your browsing patterns and the way you have interacted with this and other websites.

As you browse our website, some of the cookies placed on your computer will be advertising cookies, so we can understand what sort of pages you are interested in. We can then display advertising on your browser that is based on these perceived interests. These cookies do not contain personal or financial information about you, but may contain a unique identifier required by the retargeting process. If you access one of these ads, we may also track the response rate and the website activity associated with it.

We also work with third party advertising providers who collect and use information about your visits to this and other websites (but not your name, email address, postal address or phone number) to show you advertising that may be of interest to you.

Other information

We may amend this Privacy Policy from time to time to take into consideration changes in legislation or other issues that may arise. We will post the revised Privacy Policy on our public websites including atwww.fmic.ca. We may also send it to you by mail.

We reserve the right to change or remove this Privacy Policy at our discretion. If we decide to change it, we will post those changes here. We encourage you to visit this area frequently to stay informed. If you access our website after we have posted changes to this policy, you are agreeing to accept the changes. 

You can find out more information about your rights by visiting these websites:

Office of the Privacy Commissioner of Canada

Addressing Your Concerns

You are always in control of your personal information. Providing us with your information is always your choice. By establishing an account with us, you have consented to the disclosure of your personal information to third parties in the circumstances or for the purposes described in this policy. Your decision to withhold information or withdraw consent with respect to our use of your personal information may prevent us from taking you on as a client, providing you with the best possible service, or continuing to work with you as a client. You can withdraw your consent at any time, subject to the requirement of reasonable notice and any legal or contractual restrictions, by writing to us.

As set out in the introduction to this policy, if you’d like to know more about our policy, or have questions about how we manage your personal information, please contact our Privacy Officer, Amber Kehoe, at [email protected] or 613-279-3061. You can also get in touch with our Privacy Officer at:

Frontenac Mortgage Investment Corporation.

Sharbot Lake, ON K0H2P0
Attn: Privacy Officer

Please reach out to us if you have any comments, questions or concerns about this policy or your personal information. If you choose to mail, fax or email us, please include your full name, address, and telephone number.