Privacy Policy
[Last update: August, 8th, 2023]
Brightwise Media Inc. (doing business as CompareMortgages.ca and hereinafter referred to as “Brightwise”, “we”, “us”, and “our”) is committed to the privacy and security of your personal information. This privacy policy (or “Policy” for short) describes how we collect, use, and disclose your personal information, how we protect it, and the controls you have over it.
This Policy applies to the websites controlled by Brightwise, including the CompareMortgages.ca website (“Sites”), and any services rendered or made available through the Sites, including your interactions with us in the course of your use thereof whether by phone, email, online chat or otherwise. This Policy does not extend to websites, mobile applications or other services of third parties. We are therefore not liable for their privacy policies, procedures and practices.
BY SUBMITTING PERSONAL INFORMATION TO BRIGHTWISE OR ITS SERVICE PROVIDERS AND AGENTS, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY AND AS PERMITTED OR REQUIRED BY LAW. SUBJECT TO LEGAL AND CONTRACTUAL REQUIREMENTS, YOU MAY REFUSE OR WITHDRAW YOUR CONSENT TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AT ANY TIME BY CONTACTING OUR PRIVACY OFFICER, WHOSE CONTACT INFORMATION IS SET OUT BELOW. IF YOU REFUSE OR WITHDRAW YOUR CONSENT, WE MAY NOT BE ABLE TO PROVIDE YOU OR CONTINUE TO PROVIDE YOU WITH SERVICES OR INFORMATION WHICH MAY BE OF VALUE TO YOU.
Please review this Policy before providing us with your personal information, using the Sites or our services. If you do not agree with this Policy, do not provide us with your personal information, use the Sites or our services.
This Policy is divided into the following sections.
- What Information Is Collected
- How We Collect Your Personal Information
- Why We Collect and Use Your Personal Information
- To Whom We Disclose Your Personal Information
- Cross-Jurisdictional Transfers
- Protection of Your Personal Information
- How Long We Retain Your Personal Information
- Your Rights
- Links to Other Websites and Advertising
- Changes to This Policy
- Contact
- What Information Is Collected
For the purpose of this Policy, “Personal Information” includes any information which relates to a natural person and allows that person to be identified directly, or indirectly in combination with other information. It does not include personal information where all references to the identity of the relevant individual have been removed (i.e., anonymous personal information).
We may collect, use, and disclose the following categories of personal information about you, including but not limited to:
- Identification Information, such as your first name and last name, preferred name;
- Contact Information, such as your province of purchase, email and telephone number;
- Property and Price Information about a property that you wish to finance, purchase price, if you will live in the property, down payment amount, status of your current or planned offer to purchase a property, generally how you would rank your credit (Excellent, Good, Fair, or Poor);
- Client Communications, such as messages, opinions, complaints, evaluations, questions, or comments that you provide to us, as well as your contact information and the content of your message;
- Technical Information, such as internet protocol (IP) address and geolocation information, cookies and other technology on the devices you use to access the Sites; and
- Internet Activity Information, such as browsing history, search history, and interactions with our Sites and online advertisements. In addition, we may collect information about your browsing behaviour, such as the date and time you visit the Sites, the areas or pages of the Sites that you visit, the amount of time you spend viewing the Sites, the number of times you return to the Sites, the websites that you visit before or after you visit our Sites and other click-stream data.
- How We Collect Your Personal Information
- Information that You Provide
Some personal information is provided to us voluntarily by you (for example, when you complete our click-through form and request that we contact you for our services) while some personal information is collected automatically (as described below at Section 3.2).
More precisely and without limitation, we collect your personal information in the following circumstances:
- When you submit an application for a comparison of mortgage and other financing rates;
- When you communicate with us by phone, email, online chat or otherwise;
- When you submit a complaint; and
- When you schedule a meeting with one of our representatives with regards to our services.
If you consult one of our representatives by telephone, we may record the call for training and quality assurance.
If you provide us with personal information of another individual, you represent that you have obtained all necessary consents from such person to enable us to collect and process such personal information for the purposes set forth in this Policy.
- Information Collected Automatically
As you interact with our Sites, we will automatically collect Technical Information and Internet Activity Information about your equipment and browsing actions and patterns. We collect this information by using cookies, pixels, server logs and other similar technologies. We may also receive Technical Information and Internet Activity Information about you if you visit other websites employing our cookies.
A cookie is a small text file that may be stored on the hard drive of your computer when you access the Websites. We may also use cookies to: (1) provide you with customized content and interest-based advertising; (2) monitor our Sites’ usage; and (3) conduct research to improve our content and services. You are free to accept or decline cookies at any time, but by doing so, you may not be able to use certain features on the Sites or take full advantage of all our offerings. Check the “Help” menu of your browser to learn how to change your cookie preferences.
In addition, the Sites contain cookies operated by third parties. For example, we use certain third-party analytics services, such as Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting and other integrated services that require Google Analytics to collect information, including the collection of information via cookies. You can opt out of having made your activity on the services available to Google Analytics by installing the Google Analytics opt-out browser add-on. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.
We conduct interest-based advertising, also referred to as targeted advertising or behavioural advertising on our Sites. Retargeting means that the ads that you are being served are personalized based on your behaviour when browsing online. Ad serving services, advertisers, and other third parties may use tracking technologies on the Site and on the Third-Party Services (as defined below) to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third-Party Service or third-party device after you have left the Sites. For instance, our Sites use Bing, Snapchat, LinkedIn and Twitter cookies. If you are not comfortable with this, you can opt out of interest-based advertising by managing your cookies and other tracking technologies in your browser settings.
The Sites contain social media plugins provided by social media platforms in order to allow you to interact with us on these platforms. By browsing the Site, your browsing information may be transferred directly to the relevant social media platform, even without direct interaction on your part, due to the sole presence of the buttons on the Site. These cookies are not under our control. Please consult the privacy policies of each of these social media platforms to know more about their use of cookies and other tracking technologies and how they work.
In general, the information collected by cookies is not considered personal information since it cannot be used to identify you. You may set your Internet browser to reject cookies if desired; however, this may result in loss of functionality of certain features of the Sites.
Please note that we use the web analysis tool Smartlook to continuously develop our Sites and provide visitors with the best possible experience. Smartlook also uses cookies, which enable session-based analysis of your use of the website. The data generated by the cookie and other records about visits to our websites are sometimes stored, processed and made available to us by Smartlook. Smartlook only records your IP address and deletes it automatically after a period of 30 days at the latest. You can prevent the provision of your data by selecting the opt-out option: https://www.smartlook.com/opt-out/. For more information, please refer to Smartlook’s privacy policy, which can be found here: https://help.smartlook.com/en/articles/3244452-privacy-policy.
- Why We Collect and Use Your Personal Information
We may use your personal information for the purposes for which it was collected, as set out in this Policy, for other purposes permitted by law, or for other purposes with your consent.
We may use the information collected for the following purposes:
Purpose | Type of personal information |
To provide you with the products and services you have requested through the Sites | Identity personal information Contact personal information Property and Price Information |
To provide you with access to our Sites and to enhance your convenient use of our Sites | Technical Information Internet Activity Information |
Respond to any communication we receive from you | Identity Information Contact Information Client Communications |
Understand your needs and interests and provide you with optimal services and personalized advertisements, services, products and other communications | Identity Information Contact Information Property and Price Information |
Help us develop, deliver, improve and provide you with our best services, content and communications | Identity Information Contact Information Property and Price Information Technical Information Internet Activity Information |
Protect against error or fraud | All categories of information |
Comply with legal and auditing requirements | All categories of information |
Investigate breaches of the Terms of Service or the Policy | All categories of information |
Collect debts owed to us by you | All categories of information |
- To Whom We Disclose Your Personal Information
We may communicate your personal information to third parties in the following circumstances:
- with referral partners who may be able to offer you mortgage services;
- with our service providers who help us (i) fulfil the purposes for which your personal information was collected, including hosting providers and data storage and processing providers and marketing providers (including social media companies), and (ii) analyze the profiles and characteristics of our Sites’ visitors (such as research and analytics) to better understand them;
- to comply with our obligations under any law or regulation, investigation, subpoena or order of a court, tribunal or other administrative or governmental authority;
- with law enforcement or a government institution in order to investigate fraud or potential fraud, as well as any other violation of a law, regulation, or the terms and conditions of use of the Sites in order to protect the rights, property, or safety of Brightwise, our customers/users, or our partners; and
- with an acquiring organization in the event of a proposed or actual purchase (including liquidation, realization, seizure, or repossession), concession, merger, business combination, or any other type of acquisition, liquidation, transfer, translational contract, or financing of Brightwise in whole or in part or of any property, share, assets, stock, or business of Brightwise.
- Cross-Jurisdictional Transfers
By providing us with personal information, you acknowledge and agree that your personal information may be transferred to other jurisdictions for processing and storage, including in servers located across Canada and in the United States, where laws regarding the protection of personal information may be less stringent than the laws in your jurisdiction. Further, your personal information may be accessible to law enforcement, national security authorities, and the courts of such jurisdictions. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the personal information.
- Protection of Your Personal Information
To prevent unauthorized access or disclosure, maintain data accuracy and facilitate the appropriate use of data, Brightwise uses physical, technological and administrative procedures to attempt to protect the integrity of its Sites and the confidentiality of personal information that it collects, uses, and discloses. Nevertheless, Internet transmissions are never completely private or secure. Brightwise cannot be liable for any breaches of confidentiality due to system failures or unauthorized access by third parties.
- How Long We Retain Your Personal Information
Brightwise only keeps personal information for as long as necessary and for the purposes for which it was collected, or for as long as required to comply with any applicable legal obligation and its documents retention policies. The length of time personal information is kept varies according to the nature of the information, and it may extend beyond the end of the relationship between an individual and Brightwise.
When the personal information collected is no longer required by Brightwise, the necessary procedures for destroying, deleting, erasing, or converting it into an anonymous form are applied.
In some circumstances, we will anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes or other legitimate reasons, in which case we may use this information indefinitely without further notice to you.
- Your Rights
Subject to certain exceptions, as permitted by law, you have the following rights in relation to the personal information we hold about you
- Your right of access
You have the right to access the personal information we hold about you and to receive a general account of our uses of that personal information. Upon receipt of a written request from you, we will provide you with a copy of your personal information, although in certain limited circumstances, we may not be able to make all relevant personal information available to you, for example, where that personal information also relates to another individual. In such circumstances, we will, upon request, provide you with the reasons for such refusal. We will endeavour to deal with all requests for access of personal information in a timely manner.
- Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. Where appropriate, such amended personal information will be provided to the parties to whom we are authorized to disclose your personal information. Information stored in your account profile may be corrected directly by you if necessary. Information collected by cookies is stored in cookie files located on your device, and thus can be modified by you without involving us.
- Your right to portability
You may have the right, in certain circumstances, to obtain personal information you have provided us in a structured, commonly used, and machine readable format and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
- Your right to withdraw consent
If we rely on your implicit or explicit consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you, including the Services. We will advise you if this is the case at the time you withdraw your consent. We may use your information to send important notices or communications regarding your orders, even if you have opted out from our marketing communications.
- Links to Other Websites and Advertising
The Sites may occasionally contain links to other sites not operated by Brightwise (“Third Party Services”). Brightwise is not responsible for the privacy practices or the content of those websites. Please be sure to review the privacy policies of those sites.
The Site may display advertisements and/or links to third party sites. These advertisements or links may contain cookies placed by those third parties. Brightwise is not responsible for those advertisements, the sites to which they are linked, or how any other linked sites may use their own cookies or information. For example, cookies received with banner ads may be collected by the company posting the ad on Brightwise’s Site. Please refer to that company’s privacy policy for further information.
- Social Networks
The use of social networks in connection with Brightwise’s Sites may lead to the collection and exchange of some personal information between Brightwise and such social networks. We invite you to read the privacy policy posted on the social networks’ websites to be aware of what personal information can be transmitted to Brightwise as well as the purposes of processing of your personal information by such social networks, in particular for advertising purposes. You can directly configure and control the access to and confidentiality of your personal information. Brightwise shall not be responsible for any use of your personal information by social networks on their account.
- Changes to This Policy
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Sites, indicate the date of the latest version, and comply with applicable laws. Your continued use of the Sites and our services after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy. If you disagree with any changes made to the Policy, please cease to use the Sites and our services. Additionally, if you restart using the Sites and our services, you are considered to have accepted the Policy then in effect.
- Contact
If you have any questions or comments about this Policy or your personal information, or to make a request to access your personal information or have it corrected, please communicate with our Privacy Officer by email using the following contact information: privacy@Brightwise.ca