Privacy Policy

Orbis Mortgage Group is committed to protecting the personal and confidential data of our clients in accordance with government laws and as required by the Autorité des marchés financiers (AMF).

Privacy Policy

Orbis Mortgage Group is committed to protecting the personal and confidential data of our clients in accordance with government laws and as required by the Autorité des marchés financiers (AMF). As financial service providers, we have an obligation to protect the confidentiality of the information received in the course of our duties. The purpose of this privacy policy is to inform our clients of the reasons why we collect personal information, how we use it, the methods used to protect it, and how to contact us if you have any questions or concerns regarding privacy protection.

Overview

The purpose of this policy is to enhance your confidence in our company, our products and our services In our privacy policy, we set out how we collect, protect and use information about you when you visit our website.

What is personal information?

We place great importance on the trust our clients place in us; therefore, we protect the confidentiality, private details, and information collected in connection with their mortgage application, pre-approval, inquiries for a mortgage or loan, as well as insurance or any other product obtained through Orbis Mortgage Group or its affiliates, provided by, or collected by Orbis Mortgage Group and its staff or by Orbis brokers, associates, and affiliates on behalf of Orbis.

Why does Orbis Mortgage Group collect personal information?

Orbis Mortgage Group collects and uses personal information for the following purposes:

To provide mortgage brokerage services to the client and offer them products and services tailored to their needs, including the granting and/or renewal of mortgage loans, creditor group insurance, and other products offered and approved by Orbis Mortgage Group or its affiliates, which may be of interest to the client;
To check the client’s credit file by investigating with the credit bureau, as well as through personal information agents who hold information about the client’s financial position;
To inform the client about their financial options, as well as the ongoing developments in the mortgage market and industry;
Audit services provided to our clients;
To comply with municipal, provincial, federal, and other laws; and
For other specific purposes communicated to the client by a member of Orbis Mortgage Group prior to the collection of information, except where otherwise required by law, we will use the client’s personal data solely for the purposes determined with them. If personal information is required for another purpose not listed, we will first take all reasonable steps to ensure that the new purpose is identified before using it.

How do we collect your personal information?

The provision of information provided by the client to Orbis Mortgage Group signifies their acceptance and consent for Orbis Mortgage Group to collect, use, and disclose such personal information in accordance with this privacy policy. Orbis Mortgage Group will not collect, use, or disclose a client’s personal information without the necessary consent, except in certain extraordinary circumstances. Such exceptional circumstances must include, without limitation, legal, medical, or security reasons, when obtaining consent is impossible or impracticable, or when it is in the best interests of the client. The most commonly used method to obtain the client’s consent is through the client’s confirmed authorization on the credit application form, or using the form provided by the Filogix system, as mentioned above. When possible, Orbis Mortgage Group may also obtain verbal consent during an interview, followed as soon as possible by written consent (this is not recommended as a credit reporting agency may refuse this type of consent), or through a document such as an email that clearly includes the client’s name defined in the email address. Any form of written authorization must clearly state that the client authorizes the use of their information for the purpose of obtaining financing, and that such information may be used by a third party.

The client may withdraw their consent at any time by sending written notice to the address below, subject to any legal or contractual restrictions and within a reasonable timeframe. A client’s refusal to give consent, or subsequent withdrawal of consent, may affect Orbis Group’s ability to provide mortgage services to that client. A member of Orbis Mortgage Group will inform the client of the implications of this withdrawal. To withdraw their consent, the client must communicate in writing with the privacy officer at:

Attn: Mr. Theodore Kyres, President
Orbis Mortgage Group
285, Place d’Youville, bureau 9
Montréal, QC H2Y 2A4
Tél. : 514-313-0108

Use and Disclosure of Personal Information

We will use the client’s personal information to provide financial services and advice, to administer our database, to add the client to our marketing activities, or for any other use as described above in the section ‘Why Orbis Mortgage Group collects personal information’. In certain circumstances, Orbis Mortgage Group may disclose personal information to a third party. More specifically, personal information may be used, shared, and disclosed to, from, or with, members of Orbis Mortgage Group, witnesses in a legal proceeding, experts hired on behalf of the client, credit bureaus, as well as third parties necessary to facilitate the matter for which the client has retained our services and given consent. In certain circumstances, Orbis Mortgage Group may disclose personal information:

When required or authorized by law, for example, if the court issues a subpoena;
When the client has consented to the disclosure of this information;
When Orbis Mortgage Group provides mortgage services to a client for whom personal information is required by a third party (for example, by a lender during a real estate mortgage transaction); in this case, the client’s consent will be implied unless otherwise notified by the client.
When it is necessary to engage a credit bureau for the processing of a mortgage transaction;
If Orbis Mortgage Group hires a third party to provide administrative or support services (such as computer backup services or shredding and archiving of records); this third party is bound by our privacy protection policy.
For the protection of Orbis’s best interests;
For the protection of public interests or the reporting of criminal activities such as fraud or money laundering. In these situations, authorities will be contacted, and personal information may be disclosed.
If we retain the services of a law firm to act on our behalf, regardless of the reason; or
If the information is already known to the public.

Limitation of the Collection and Retention of Personal Information

Orbis Mortgage Group limits the collection of personal information from a client to those that are necessary for the purposes listed in the privacy policy, which may be amended from time to time, or for other purposes identified to the client before the collection of personal information. Furthermore, the personal information collected can only be used or disclosed for the purposes for which it was collected, except with the consent of the client or as otherwise authorized by law.

Accuracy

Orbis Mortgage Group endeavors to ensure that the client’s personal information is as accurate, complete, and up-to-date as possible for the purpose for which it is used. Before submitting a transaction to a lender, the agent must validate the information received and ensure its accuracy, in accordance with best practices. These practices involve confirming the client’s identity and carefully reviewing all documentation such as income, down payments, appraisals, purchase and sale offers, or any other document relevant to each transaction, before submitting the file to a lender. This step is necessary for the processing of each transaction to prevent any fraudulent activity. Each agent is responsible for ensuring that all information collected is accurate and fully disclosed to each lender to whom they submit their transaction for approval, as stipulated in their independent agent contract.

For agents who wish to attend our training sessions on the key points to look for when reviewing documentation during the transaction, Orbis Mortgage Group holds quarterly sessions on fraud prevention. It is also recommended for our agents to review frequently asked questions on the AMF website at www.lautorite.qc.ca.

For those with questions about standard practices, agents can inquire at the AMF contact center or by calling (514) 395-0337 for more information.

Backup

Orbis Mortgage Group strives to maintain a maximum level of security to protect data backup against loss, theft, unauthorized access, disclosure, reproduction, as well as the use or modification of the client’s personal information under the responsibility of Orbis Mortgage Group. Orbis Mortgage Group uses various methods to protect personal information, including physical security, computer and electronic security, destruction of information that is no longer needed, and contractual protections with third-party data processors. Paper copies requested by the AMF are kept at the head office for 12 months, or until they are digitized. All previous records required by the AMF are kept at the same address and are available upon request from the parties concerned.

Protection

The client list is never transmitted to a third party other than members affiliated with Orbis Mortgage Group. Upon hiring, employees and agents must commit to respecting the confidential nature of client information. Only employees and associates who need to access the records as part of their duties have access to this information.

Changes to the Privacy Policy

From time to time, Orbis Mortgage Group reviews and revises its privacy protection practices. New or modified policies will be announced on this page without delay.

The website of Orbis Mortgage Group

Our website may contain links to other sites that are not governed by this privacy policy. On our website, like on most commercial websites, we may monitor transmission habits, site usage, and related information in order to optimize our service. We may occasionally provide aggregate information to third parties, but these statistics do not include personal information revealing your identity. The website of Orbis Mortgage Group, as well as all websites of our agents, must clearly indicate the address and contact information of the head office, as well as the broker’s license number assigned by the AMF. All license numbers are also displayed on the Orbis Mortgage Group website and must be clearly displayed on the website of each agent.

Orbis Mortgage Group requires all its agents who create websites to submit all website content to our privacy and compliance officer before it is published and made accessible to the public. A quarterly review of our agents’ websites validates the maintenance of compliance. It is mentioned in the independent agent contract that each agent must sign upon hiring by our firm.

Security and Data Storage

Each agent and broker must take reasonable measures to protect the personal data provided by the client Each original document will be kept in a secure location, not accessible to the public. When a file is complete, all unnecessary documents are immediately returned to the client. If the original documentation comes from the client, it will be submitted to the head office, either on paper or electronically, before closing the transaction. Although the agent must keep a copy of the file, they are required to make every effort to protect the confidentiality of the documents in their possession, as they are responsible for safeguarding all confidential and private information entrusted to them.

It should be noted that all files are the property of Orbis Mortgage Group. Although brokers and agents retain data for marketing purposes, clients are the property of Orbis Mortgage Group.

All documentation that is no longer needed must be shredded immediately. All electronic documentation must be password protected. Laptops containing client files should never be left unattended in a public place.

The head office will take necessary measures to ensure the security of client file data. Scanned documents must be adequately protected and cataloged. All client files as well as personal records must be kept in a locked cabinet or in a secure electronic format. All computers at our head office are password protected and data is regularly backed up to our external/mobile hard drive for storage each evening at a secure off-site location. All scanned documents are shredded immediately or stored in a secure locked cabinet until they are shredded by an external firm. We are currently using the services of Iron Mountain.

Record Retention

Completed mortgage records will be retained for a period of six years following the mortgage maturity date. All non-mortgage related documents will be retained for six years. Documentation regarding cancelled or incomplete files will be retained for at least one year, except for consent forms, which must be kept on file for a period of three years in case a credit reporting agency requires proof of client consent to obtain a report. All paper copies will be shredded after this period.

Complaints

Upon receipt of a complaint from a consumer or investor, the complaints officer (or a designated person) will take immediate investigative measures. If the complaint concerns a completed file, the complaints officer will extract existing documentation from the company’s files. The complaints officer will review the documentation, then forward the complaint to the relevant agent or broker to gather their comments. If the complaint concerns an active file, the complaints officer will immediately contact the agent or broker responsible for the file and forward the complaint to them for comment. Together, they will review the file in question. The complaints officer will verbally respond to all complaints within 48 hours of receipt, and will provide written follow-up as soon as possible. If a satisfactory solution cannot be found, the written response should propose that the matter be referred to the AMF. All documentation regarding a complaint must be retained according to file processing requirements, and a copy will be kept in the human resources file of each agent, which is archived at the head office of Orbis Mortgage Group.

Complaints can be addressed directly via the Orbis website : https://groupeorbis.com/en/contact-us/

Contacting Orbis Mortgage Group

We acknowledge that ease and speed of access should not outweigh security imperatives. We use various means to communicate with our clients, some of which are more convenient, such as emails. Our emails are sent according to industry standards with 128-bit encryption. However, such encryption does not guarantee confidentiality or security as encrypted messages can be intercepted and decrypted. If the client prefers not to use email as a means of communication, they should discuss this with the consultant/broker/agent managing their file to find an alternative solution.

Attn: Mr. Theodore Kyres, President
Orbis Mortgage Group
285 Place d’Youville, bureau 9
Montréal, QC H2Y 2A4
Phone: (514) 313-0108