Privacy Policy

Castleton Financial Ltd. ("Castleton") is committed to protecting the confidentiality of your personal information in accordance with Quebec's Act Respecting the Protection of Personal Information in the Private Sector (Law 25 / Bill 64), the Civil Code of Quebec and applicable federal legislation. This policy describes the measures we take to honour those commitments.

1. Information we collect

When you use our website, submit a mortgage application or provide a guarantee, we may collect: your name, contact details, date of birth, social insurance number (SIN), income, assets, liabilities, source of funds, references, financial and employment records, property details and any other information you voluntarily provide.

Information is considered sensitive when it is medical, biometric or otherwise intimate, or when, due to its context, it gives rise to a high reasonable expectation of privacy.

2. Why we collect your information

We collect personal information to:

• Identify you and understand your needs;
• Determine eligibility for our private mortgage products;
• Validate the accuracy of file information;
• Inform you of relevant products and services;
• Improve our services and interactions with you;
• Comply with legal and regulatory obligations (FINTRAC, Law 25, Civil Code of Quebec);
• Protect your interests and ours.

If a new purpose arises, we will obtain your consent before using your information for that purpose.

3. How we collect your information

In addition to information you provide directly, we may obtain and verify information from credit bureaus, mortgage insurers, public registries, notaries and other persons with whom you have or have had a financial relationship — to the extent permitted by law. You have the right to know the source of personal information we hold about you.

4. Consent

We will take reasonable steps to ensure you understand why we are collecting your information, how we collect it, and what we may do with it. You can give consent orally, in writing or electronically, and may withdraw it at any time by reasonable written notice. Withdrawing consent may affect our ability to provide certain products.

5. Disclosure of your information

Your information is accessible only to employees, agents and service providers who need it to perform their duties. We have written agreements with all our partners to ensure they preserve the confidentiality and security of your information.

Your information may also be disclosed without your consent in cases provided by law: fraud prevention, security, emergencies, legal obligations (including FINTRAC Know-Your-Client requirements) or privacy incident management.

6. Retention and destruction

We retain your personal information only as long as necessary for the identified purposes or as required by law — generally up to seven years for mortgage records, in accordance with FINTRAC requirements and the Civil Code of Quebec. After the retention period, information is destroyed, erased or anonymized.

7. Security

We ensure the physical, organizational and electronic security of your personal information. In the event of a privacy incident presenting serious risk, we will notify you and the Commission d'accès à l'information du Québec, and we maintain a register of privacy incidents for five years.

8. Your rights under Law 25

You have the right to:

• Access the information we hold about you;
• Have it corrected or deleted if inaccurate or out of date;
• Withdraw your consent at any time;
• Know the categories of persons who have access to your information;
• File a complaint with the Commission d'accès à l'information du Québec.

All access or correction requests must be made in writing. We will respond within 30 days.

9. Cookies and analytics

Our website uses cookies to improve your experience. You may disable them in your browser settings. Analytics data is anonymized and is never linked to your personal information.

10. Transfers outside Quebec

When required by the nature of your file, some of your personal information may be communicated to or hosted outside Quebec — for example with email, cloud hosting or productivity providers whose servers are located elsewhere in Canada or in the United States, or with FINTRAC for legally required reporting.

Before any transfer of personal information outside Quebec, we conduct a privacy impact assessment (PIA) in accordance with section 17 of Law 25. The assessment takes into account the sensitivity of the information, the purpose of its use, the contractual and technical safeguards in place and the legal framework applicable in the destination jurisdiction. Every transfer is governed by a written agreement that imposes on our partner obligations equivalent to those required by Law 25.

You may at any time request details about transfers concerning you by contacting our Chief Privacy Officer (see section 11).

11. Privacy officer

In accordance with section 3.1 of Law 25, Castleton has designated a Chief Privacy Officer. For any question, complaint, access request, correction request or inquiry about transfers outside Quebec, contact:

Marc Bissell, Chief Privacy Officer
Castleton Financial Ltd.
3636 avenue du Musée, Montréal, QC H3G 2C9
Phone: 514.924.9485 · Toll-free: 1.877.245.4646
Email: info@preteur.com

If you believe your request has not been handled to your satisfaction, you may file a complaint with the Commission d'accès à l'information du Québec at 1-888-528-7741 or at cai.gouv.qc.ca.