On this page
- Introduction and Scope
- What Personal Information We Collect
- Why We Collect Your Information (Purposes)
- Consent
- Use and Disclosure of Your Information (Including Sharing with BRX Mortgages and Lenders)
- Cookies, Meta Pixel and Analytics
- Third-Party Processors and Cross-Border Storage
- Data Storage and Retention
- Safeguards and Security
- Your Rights: Access, Correction, and Withdrawing Consent
- How to Contact Our Privacy Officer
- Changes to This Privacy Policy
1. Introduction and Scope
Everpath Mortgages, a marketing/team name of mortgage agents licensed under BRX Mortgages ("we," "us," or "our"), operates the website located at [website URL] (the "Site"), an informational landing page through which Ontario residents can request information about mortgage and debt-related options and book a strategy call. We respect your privacy and are committed to protecting the personal information you share with us. This Privacy Policy explains what personal information we collect, why we collect it, how we use and disclose it, how we obtain your consent, and the choices and rights available to you. We handle personal information in accordance with the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Ontario law. By using the Site or submitting information through our forms, you acknowledge that you have read and understood this Policy. If you do not agree with our practices, please do not submit your information or use the Site.
2. What Personal Information We Collect
We collect personal information that you voluntarily provide when you complete a form on the Site, request a consultation, or book a strategy call. This typically includes: your full name; telephone number; email address; and details about your financial situation that you choose to share, such as your debt amounts, debt types, mortgage or home-ownership status, income range, and the goals you are trying to achieve. We treat financial information as sensitive information and collect only what is reasonably necessary to assess how we may be able to help you and to arrange a consultation. We also automatically collect certain technical information when you visit the Site, such as your IP address, device and browser type, operating system, referring website, pages viewed, and interactions with the Site, collected through cookies and similar technologies as described in the "Cookies, Meta Pixel and Analytics" section below. We do not knowingly collect personal information from anyone under the age of majority in Ontario, and our Site is not directed at minors.
3. Why We Collect Your Information (Purposes)
We identify the purposes for which we collect your personal information at or before the time of collection, as required by PIPEDA. We collect and use your personal information to: (a) respond to your inquiry and contact you by phone, email, or text message; (b) assess your general situation and determine whether and how we, or our brokerage partner, may be able to assist you; (c) schedule, confirm, and conduct strategy calls and consultations; (d) connect you, where appropriate and with your consent, to a licensed mortgage professional or lender who may be able to offer products or services relevant to your needs; (e) send you information, follow-ups, and marketing communications about our services, where you have consented to receive them; (f) operate, maintain, secure, and improve the Site and our services; and (g) comply with our legal and regulatory obligations. We will not use your personal information for purposes that are materially different from those described here without first obtaining your consent, unless permitted or required by law.
4. Consent
We collect, use, and disclose your personal information only with your knowledge and consent, except where PIPEDA permits or requires otherwise. By submitting a form on the Site, you provide your express consent for us to collect the information you supply and to use and disclose it for the purposes described in this Policy, including contacting you and sharing your information with our brokerage partner and, where appropriate, a lender. Because financial information is sensitive, we rely on your express, opt-in consent for its collection and use. Where you provide a telephone number or email address, you also consent to being contacted at that number or address, including by automated tools, in connection with your request. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us using the details in the "How to Contact Our Privacy Officer" section. Withdrawing consent may mean we are unable to provide you with some or all of our services or to continue assisting you with your inquiry. The form of consent we seek may vary depending on the sensitivity of the information; for less sensitive technical information collected automatically, we may rely on implied consent as described below.
5. Use and Disclosure of Your Information (Including Sharing with BRX Mortgages and Lenders)
We use your personal information only for the purposes for which it was collected, or for a use consistent with those purposes, unless you consent to a new use or the use is permitted or required by law. We share your personal information with our affiliated brokerage, BRX Mortgages, and with the individual mortgage agents or brokers working with us, so that a licensed professional can review your situation, contact you, and explore appropriate options. With your consent, we may also disclose relevant information to one or more lenders, financial institutions, or other service providers in order to seek or arrange a mortgage or financing solution that may suit your needs. We may further disclose personal information: to third-party service providers who process information on our behalf (such as our customer relationship management and form platform, and our advertising and analytics providers), under contractual safeguards limiting their use of the information to the services they provide to us; to professional advisors such as lawyers and accountants; in connection with a sale, merger, or reorganization of our business; and where required or permitted by law, including to comply with a court order, subpoena, regulatory request, or to detect and prevent fraud. We do not sell your personal information.
6. Cookies, Meta Pixel and Analytics
The Site uses cookies, pixels, software development kits, and similar tracking technologies to operate the Site, understand how visitors use it, measure the performance of our advertising, and deliver and optimize ads. In particular, we use the Meta Pixel and related conversion tracking tools provided by Meta Platforms, Inc. (Facebook and Instagram), and we may use web analytics tools such as Google Analytics. These technologies may collect information such as your IP address, device and browser information, pages and ads you interact with, and actions you take on the Site (for example, submitting a form), and they may set cookies or identifiers that allow Meta and other providers to recognize your device across websites and to show you advertising on their platforms. This may involve the use of your information for online behavioural (interest-based) advertising. Consistent with the guidance of the Office of the Privacy Commissioner of Canada, we do not use sensitive financial details you submit through our forms for behavioural advertising, and we limit pixel-based tracking to non-sensitive interaction data. We obtain consent for non-essential cookies and tracking technologies through [our cookie banner / consent tool], and you can manage or decline non-essential cookies at any time. You can also opt out of interest-based advertising through your Meta ad preferences and account settings, your browser controls, and tools such as the Digital Advertising Alliance of Canada opt-out page at youradchoices.ca, or by adjusting the cookie settings provided on the Site. Opting out does not delete cookies already stored on your device, which you can remove through your browser settings.
7. Third-Party Processors and Cross-Border Storage
We use third-party service providers to help us operate the Site and our business. These include GoHighLevel (HighLevel Inc.), which hosts our forms and customer relationship management and communication tools, and Meta Platforms, Inc. and [Google LLC], which provide our advertising, pixel, and analytics services. These providers process personal information on our behalf or, in the case of advertising and analytics platforms, also as independent controllers for their own purposes as described in their respective privacy policies. Some of these providers, and the servers on which your information is stored, are located in the United States or other countries outside Canada. As a result, your personal information may be stored and processed outside of Canada and may be subject to the laws of those jurisdictions, including lawful access by foreign courts, law enforcement, and government authorities. We use contractual and other measures intended to provide a comparable level of protection while your information is being processed by our service providers. By submitting your information, you acknowledge that it may be transferred to, stored in, and processed in jurisdictions outside Canada.
8. Data Storage and Retention
We retain your personal information only for as long as is reasonably necessary to fulfill the purposes for which it was collected, to provide and follow up on our services, to maintain records of consent and communications as required under PIPEDA and CASL, and to satisfy our legal, regulatory, accounting, and reporting obligations. The retention period varies depending on the nature of the information and the reason it was collected; for example, we retain records of your consent and our communications with you for at least the periods required by applicable anti-spam and privacy legislation. When personal information is no longer required for any legal or business purpose, we will securely destroy, erase, or anonymize it. If you ask us to delete your information or withdraw your consent, we will do so subject to any records we are legally required to retain.
9. Safeguards and Security
We protect personal information using physical, organizational, and technological safeguards appropriate to the sensitivity of the information. These measures include restricting access to personal information to staff and partners who need it to perform their duties, using reputable service providers that maintain industry-standard security controls, employing encryption in transit where appropriate, and using authentication and access controls on the systems where your information is stored. While we take reasonable steps to safeguard your information, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping any account credentials and the device you use to contact us secure. If we become aware of a breach of security safeguards involving your personal information that creates a real risk of significant harm, we will notify you and the appropriate authorities as required by law.
10. Your Rights: Access, Correction, and Withdrawing Consent
Under PIPEDA you have the right to: (a) access the personal information we hold about you and to be informed of how it has been used and to whom it has been disclosed; (b) request correction of any personal information that is inaccurate or incomplete; and (c) withdraw your consent to our collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. To exercise any of these rights, please contact our Privacy Officer using the details below. We may ask you to verify your identity before responding in order to protect your information. We will respond to access requests within the timeframe required by PIPEDA (generally 30 days), and we will inform you if there is any cost associated with responding. If we are unable to provide access or make a correction, we will explain why and note your disagreement on the file where appropriate. You may also unsubscribe from our marketing communications at any time using the unsubscribe mechanism in our messages or by contacting us.
11. How to Contact Our Privacy Officer
If you have questions, concerns, or complaints about this Policy or our handling of your personal information, or if you wish to exercise your rights, please contact our Privacy Officer: Privacy Officer Everpath Mortgages c/o BRX Mortgages [Mailing Address] [City], Ontario [Postal Code] Email: [privacy@yourdomain.com] Phone: [phone number] We will acknowledge and investigate all complaints. If you are not satisfied with our response, you have the right to contact the Office of the Privacy Commissioner of Canada at 30 Victoria Street, Gatineau, Quebec K1A 1H3, by telephone at 1-800-282-1376, or through its website at www.priv.gc.ca.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we make changes, we will revise the "Last Updated" date at the top of this page and post the updated Policy on the Site. Where the changes are material, we will take additional steps to notify you as required by law or seek your renewed consent where appropriate. Your continued use of the Site or submission of information after the updated Policy is posted constitutes your acknowledgment of the changes. We encourage you to review this Policy periodically.