1. About Fintracker

Our Services allow real estate agents (our "Customers") to obtain information relating to their clients ("Clients") for legal and professional compliance purposes relating to the execution of real estate transactions.

When we process Client personal information, we do so as a service provider to our customer. Our customer controls and is accountable for the Client personal information.

We control and are accountable for any personal information that we collect about our customers.

2. What Personal Information does Fintracker collect?

We collect the following information from our customers when they register to become a user of the Services:

1. Customer name
2. Customer complete physical address
3. Customer alternate contact information
4. Customer birth month and year
5. Password(s) customer is asked to create in order to use the Service
6. Answers to security questions customer is asked when they register for the Service
7. Customer's selected preferences, such as primary language of Service (English or French), etc.

We also collect other personal information that a customer may choose to provide if they contact us.

We also collect certain information automatically when a customer accesses the Services through our Platform, including the type and version of the electronic device(s) Customer uses to access the Services, and the dates and times on which the Customer uses the Services.

On behalf of our customers, we also collect, process and store personal information relating to our Customer's Clients. This may include the information collected on the Canadian Real Estate Association forms (Individual Identification Information Record, Corporation/Entity Identification Information Record and Receipt of Funds Record), as well as information collected through third party identity verification service providers.

The Client personal information we collect on behalf of Customers may include:

1. Client name, contact information and date of birth
2. Transaction property address
3. Sales representative/broker name
4. Date on which the customer's credit file was consulted
5. Nature of customer's principal business or occupation
6. A copy of, and information collected from, federal/provincial/territorial government-issued photo ID
7. Name of Canadian Credit bureau holding the credit file and reference number of credit file
8. Name of source verifying an individual identity (e.g. government/financial entity/utility provider) and account or reference number
9. Measures taken to ascertain the identity of an unrepresented individual
10. Relationship between third party and customer, where the customer acts on behalf of a third party
11. Determination of the risk of a money laundering or terrorist financing offence for a customer: assessed level of risk and explanation
12. Receipt of Funds Record, including transaction and payment information, as required to be completed by a REALTOR member for every amount of funds received in the course of a single purchase or sale real estate transaction

3. How does Fintracker use the personal information it collects?

Fintracker uses Customer Personal Information to:

1. Initiate and provide Customers with the Service and access to the Portal
2. Provide Customers with ongoing technical support
3. Provide ongoing administration of the Customer's registration
4. Respond to Customer questions and otherwise communicate with Customers regarding our Services and the Portal
5. Provide current and prospective Customers with relevant ads
6. Comply with legal requirements such as a law, regulation, search warrant, subpoena or court order
7. Maintain the security of the Platform and Services and detect, prevent, or otherwise address fraud, identity theft, or other technical issues
8. Protect the rights, property or safety of Fintracker, our employees or customers, or the public, as required or permitted by law.

Fintracker uses Client personal information to provide the Services to our Customers. Our customer's use of Client personal information is governed by our customer's privacy policies.

Fintracker may also use personal information to generate aggregated non-identifying information for research and analysis, and in order to improve the Service or our Portal

4. When may Fintracker Disclose Customers' Personal Information?

Fintracker collects Client personal information on behalf of its customers. As such, all Client personal information will be accessible to the Customer and the Customer's brokerage, who will use the information in accordance with their own privacy policies.

Fintracker may transfer personal information to service providers, including affiliates acting in this capacity, to perform certain services on our behalf, such as developing, maintaining, or hosting the Platform, marketing and analytics services, payment processing ad other services. We require service providers to use the personal information we provide solely for the purposes of providing services to us and to have appropriate safeguards for the protection of that personal information. Some of our service providers may be located outside of Canada, including in the United States. If you have any questions about our use of service providers, please contact us.

We may also use and disclose personal information to parties connected with the proposed or actual financing, insuring, sale or other disposal of all or part of our business or assets, for purposes connected to evaluating or performing the transaction.

We may also share personal information:

• As instructed or directed by the Customer or Client
• With our professional advisors, such as lawyers and accountants
• Where necessary to comply with our legal, regulatory, or professional obligations, or
• As otherwise permitted our required by law.

5. Cookies

We use cookies to collect limited usage information when you visit our website and to maintain your authenticated session between the login process and the application. Cookies are strictly necessary to keep your session active after you log in and to allow access to and use of the application. The application cannot be used without cookies enabled. It is our policy to use cookies to ensure secure, reliable, and efficient operation of our website and application.

Declining cookies

If you are concerned about cookies, most browsers permit individuals to decline cookies. To learn how you may be able to reduce the number of cookies you receive from us or disable cookies that have already been installed in your browser's cookie folder, please refer to your browser's help menu or other instructions related to your browser. You can also learn more about cookies by visiting www.allaboutcookies.org.

Please note that disabling or declining cookies will prevent the application from functioning, and you will not be able to log in or use the application.

6. Your rights with respect to your personal information

Fintracker endeavors to ensure that the personal information in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If a customer demonstrates that personal information is inaccurate, incomplete or out of date, we will revise the personal information and, if necessary, use its best efforts to inform third party service providers or contractors which were provided with inaccurate information so that those third parties may also correct their records.

Customers can request access to or correction of their personal information in our control by writing to our privacy officer as described in the Contact Us section below. We will respond to Customer requests within a reasonable time, generally no later than 30 days following the request. To guard against fraudulent requests, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections.

We will endeavour to provide information from our records in a form that is easy to understand. Fintracker will not charge Customers for verifying or correcting their information, however, to the extent permitted by applicable law, there may be a minimal charge imposed if you need a copy of records.

Fintracker does not control Client personal information. Clients must make any rights requests directly to the applicable Customer.

We keep Customer Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of the Customer's relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. When Customers' Personal Information is no longer required for Fintracker' purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form.

We retain Client Personal Information in accordance with our contractual obligations to our customers.

7. Safeguarding

Fintracker endeavours to maintain appropriate physical, procedural and technical security measures designed to protect personal information in our control against loss, misuse, unauthorized access, disclosure, or modification. This also applies to our disposal or destruction of personal information. Fintracker restricts access to personal information to those employees that require access to for the purposes described in this privacy policy.

To enhance the protection of your personal information, Customers should protect their devices with a passcode and sign out of the Platform after use to avoid data from being accessed or copied if the device is lost or stolen.

8. Links to other websites

Fintracker may provide links to, or automatically produce search results for, third-party web sites or resources or third-party information referencing or linking to third-party web sites or resources. Fintracker has no control over such third-party Web sites and resources, and Customer and Clients acknowledge and agree that Fintracker is not responsible for the content or information contained therein. When Customers or Clients follow such a link, this privacy policy will no longer apply, and we encourage all Customers and Clients to read the privacy statements or other disclaimers of such other parties. Fintracker is not responsible for the privacy or security practices or the content of non-Fintracker web sites, services, or products.

9. Contact Us

If you are a customer and would like to exercise any of your rights with respect to your personal information, or have any questions, concerns, or complaints regarding our collection, use, or disclosure of personal information, please write to our Privacy Officer at info@fintracker.ca.

As we do not control Client personal information, Client should contact the applicable Customer with any requests, inquiries or complaints regarding their client's personal information.

10. Changes to this Privacy Policy

This privacy policy is effective as of the last updated date below. Fintracker may update this policy from time to time, including if our practices change or if the law requires changes to it. We will post any updated privacy policy on our Platform. We encourage Customers to review this policy regularly for any changes. Customer's continued use of the Services or Platform following the posting of any changes to this policy constitutes Customer's acceptance of the revised policy.