Lanyard Financial Corporation, Lanyard Investments Inc. and affiliated/associated entities
Definition of Personal Information
“Personal Information” is any information that is specific to you as an individual and includes your residential address, date of birth, age, marital status, education, employment history, identification numbers, financial information and credit records. It does not include business contact information that is available in public records.
LFC is responsible for Personal Information under its control or in its custody and its Privacy Officer is accountable for LFC’s compliance with the principles described in this Policy. The LFC Privacy Officer may be contacted as follows:
Lanyard Financial Corporation
Attention: Privacy Officer
210-2112 West Broadway
Vancouver, BC V6K 2C8
COLLECTION PURPOSES AND USE OF YOUR PERSONAL INFORMATION
LFC will identify and document the purposes for which it collects the Personal Information before or at the time of collection. In most situations where you are asked to provide Personal Information, it will be readily obvious to you why we are collecting such information and how we will use it.
If you are an investor in one of our affiliated or associated lending entities, we will collect, as part of the subscription process, your name, address, telephone number, email address, banking information and social insurance number primarily for the purposes of being able to communicate with you, to be able to remit distributions to you, and to prepare income tax and other reporting required by law.
If you are a borrower, guarantor, indemnifier or similar or related obligor in relation to a financing or proposed financing, we will collect, as part of the loan approval and underwriting process, customary contact information such as your name, address, telephone number, and at times your personal financial information to be able to communicate with you and for the purposes of determining your creditworthiness, to facilitate our underwriting activities and to assist in future enforcement and collection of the loan.
Depending on how you do business with us, we may gather Personal Information from sources such as the following:
We may collect from and use, and disclose Personal Information to, any person or organization to:
We may use third party service providers to assist us with various services such as legal services, accounting and audit, title insurance, mortgage default insurance, mortgage administration, printing, collection of accounts, mail distribution and marketing and we may release information about you to them.
We may collect, use and disclose your social insurance number for income tax reporting purposes but also to verify and report credit information to credit reporting agencies and to verify your identity. Your social insurance number may be used to keep your Personal Information separate from that of other clients with similar names. You may refuse to consent to its use and disclosure for purposes other than required by law.
If we syndicate, assign or finance a loan or mortgage in which you are the borrower or a guarantor, or if we syndicate, assign or finance a loan or mortgage in relation to which you are, directly or indirectly, an investor, or if we sell parts of our business, or merge or amalgamate with other entities, we may release the information we hold about you to the prospective purchaser, assignee or financier as part of their due diligence and on completion of the transaction.
When you apply, as a borrower, guarantor or otherwise in relation to a loan we may exchange information about you with credit bureaus for the purpose of establishing your creditworthiness and maintaining the reliability of the credit reporting system. If you use a mortgage broker or other third party to assist you in your credit application, we may obtain and exchange information with them in order to determine your eligibility for credit.
We may verify relevant information you give us with your employer or your references and you authorize any person whom we contact in this regard to provide such information to us. We may monitor or record any telephone call we have with you. We will retain the content of the call. This is to maintain an accurate record of the information you provide and to ensure that our service levels are maintained.
CONSENT TO COLLECT, USE OR DISCLOSE YOUR PERSONAL INFORMATION
With certain exceptions as outlined below, we will obtain your consent to collect, use or disclose Personal Information.
If you are an investor, by completing and signing a subscription agreement and related documentation, you are giving us your express consent for us to use the Personal Information provided by you in the ways outlined above or in the documentation provided to you at the time or as required or permitted by law or other rules and regulations governing us and our business.
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:
Without limiting the generality of the foregoing, by submitting Personal Information to us in or pursuant to an application, completing a form, or by providing a personal financial statement to us in connection with a prospective or actual mortgage financing, you consent to our necessary collection, use and disclosure of such Personal Information in order to provide financing, products and services.
The following are exceptions where we may collect, use or disclose Personal Information without consent and for which you may not withdraw consent:
Where you are permitted to withdraw your consent, and you do withdraw your consent, we will do our best to make sure that our files are updated in this regard as quickly as possible. You must give us reasonable notice of your withdrawal of consent in writing.
Subject to the terms hereof, to withdraw your consent, simply contact us in writing and advise us of what Personal Information you no longer wish us to use.
SECURITY OF YOUR PERSONAL INFORMATION
LFC will take reasonable steps to protect Personal Information with reasonable security safeguards appropriate to the sensitivity of the information. We will use reasonable safeguards to protect personal information from theft, modification, unauthorized access, collection, use, disclosure, loss and destruction. However, we will not be responsible in relation to the events listed above if done by a third party. We will take reasonable care in disposing of personal information.
LIMITS ON COLLECTION OF PERSONAL INFORMATION
LFC will limit the collection of personal information to that which is reasonable and necessary for the purposes identified by it and for purposes that are reasonable. Personal information will only be collected by fair and lawful means.
LIMITATION ON USE, DISCLOSURE, AND RETENTION OF YOUR PERSONAL INFORMATION
REQUEST FOR ACCESS TO PERSONAL INFORMATION
Upon a request in writing, within a reasonable time LFC will inform you of the existence, use, and disclosure of your Personal Information, and you will be given access to that information, except where the law requires or permits us to deny access. For example, we will not disclose Personal Information to you if the disclosure would reveal Personal Information about another individual. There may be a reasonable cost attached to the request depending on the type and amount of information requested, such as copying or postage fees.
Furthermore, except where the law requires, we will not provide you with Personal Information if it:
REQUESTS FOR CORRECTION
The law permits individuals to submit written requests to us to correct errors or omissions in their Personal Information that is in our custody or control. We will:
QUESTIONS OR CONCERNS
If you have any questions with respect to our Policy concerning the handling of your Personal Information under our custody and control, or make a complaint, please direct your inquiries in writing to the LFC Privacy Officer.
We will ensure that any Personal Information provided by an individual while using this website is collected, used and disclosed in accordance with the Policy.
Should you not accept the conclusion of LFC’s Privacy Officer, you may contact the Information and Privacy Commissioner of British Columbia:
Privacy Commissioner of British Columbi