Privacy Policy

This Privacy Policy generally applies to any personal information (as defined below in the section entitled Definition of Personal Information) collected or generated by Abbella Financial Ltd., its brokers or anyone acting as an agent on our behalf ("Authorized Agent"), from or about its customers and other individuals which whom it deals, which may include potential customers as well as any other additional person named on an account, in any form.

At any time that you do business with Abbella Financial Ltd., and/or an entity within the M3 Mortgage Group, participate in a contest or promotion run by Abbella Financial Ltd., a Abbella Financial Ltd. broker or with an Authorized Agent, or interact with us in any manner, you are protected by the rights and safeguards contained in this Privacy Policy and you explicitly agree to its terms.

This Privacy Policy also governs personal information collected about Abbella Financial Ltd.'s website users and explains how we use and disclose personal information that we collect from users who visit our website and otherwise interact with us through abbella.ca ("website"). It also explains how we use cookies and similar technologies.

When used in this Privacy Policy, personal information means "any information about an identifiable individual". This may include, for example:

• Your name and contact information
• Email address
• Information relating to your account with us, including your identity and the mortgage you take out
• Credit and banking information
• Billing records and any complaints documented in a file
• Other types of more technical information when you interact with us through our website, when this information can identify you as an individual

Personal information that is aggregated and cannot be associated with an identifiable individual is not considered to be personal information.

We collect most of our information about you directly from you, with your consent.

We usually collect your name, address, phone number(s), email address, occupation, employer's name, birth date, annual income, net worth, assets, liabilities, credit history, investment objectives, banking information, as well as other account and payment information, including information pertaining to your use of our products and services when you register to Abbella Financial Ltd. services.

We may also collect other information such as your social insurance number, driver's license or passport number, when required and/or authorized by law, for instance to fulfill regulatory and other governmental obligations and to distinguish you from other clients with similar names.

We may also obtain information about you from third parties, with your consent. For example, for credit evaluation purposes, we may need to determine your creditworthiness through contact with an independent credit reporting agency or another source, which may include account information. Abbella Financial Ltd. uses this information to help determine the product or service that is suitable to your mortgage needs.

Purposes of Collection

Abbella Financial Ltd. generally collects personal information from or about its customers and other individuals with whom it deals for the following purposes:

• To confirm and/or authenticate customers' identity, to determine customers' eligibility for Abbella Financial Ltd.'s products and services and as necessary, to establish or verify the credit of customers that use, or intend to use, one or more of the products or services offered by Abbella Financial Ltd.
• To process customers' applications or requests, to provide the products or services that it offers, or receive the products or services that it requests, and ensure that all related transactions are supported and implemented
• To monitor, review and improve customer service, manage its business, establish, develop and preserve its business relationship respectively with its customers and other individuals with whom it deals
• To create, establish and administer customers' mortgage financing or accounts and to respond to customer or supplier inquiries
• For internal training and quality assurance purposes, to meet legal and regulatory requirements and to allow Abbella Financial Ltd. to meet contractual requirements relating to the products and services provided to customers
• To understand and assess the interests, wants and changing needs of customers with a view to improving its products and services and developing new ones, and to provide personalized products and services as well as product recommendations to customers
• Subject to our customers' Right to Withdraw Consent, to conduct surveys on the quality of our products, services or customer service or to provide our customers with offers for additional products and services that we feel may be of interest to our customers or that we believe meet our customers' changing needs

If you have applied for employment with Abbella Financial Ltd., the personal information submitted with your job application will be used for recruitment and other customary human resources purposes.

Unless required or authorized by law, Abbella Financial Ltd. will not collect or use personal information for any other or new purpose without obtaining further consent.

Abbella Financial Ltd. offers you the opportunity to use simulators. These simulators are designed to collect information about you or your financial situation. The details are then used to establish your type of profile with a view to helping you choose the most suitable product for your particular needs.

Abbella Financial Ltd. obtains consent from the individuals concerned for the collection, use or disclosure of personal information through various means. The most common method we use to obtain a customer's consent is by way of the customer's consent as confirmed by consent forms. Where practicable, we may also obtain a customer's consent through electronic communications or other written documentation.

In general, by requesting Abbella Financial Ltd. products and services and/or submitting information to us in connection with using Abbella Financial Ltd. products and services, you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Policy and in the Abbella Financial Ltd. contractual documents. Moreover, by visiting, interacting with and/or using our websites, you agree to benefit from, be bound by, the terms and conditions of this Privacy Policy.

Exceptional Circumstances

In certain circumstances, personal information may be collected, used or disclosed without consent. These exceptional circumstances may include:

• When information is being collected, used or shared for the detection, prevention of or remediation to, the breach of an agreement, fraud or other illegal activity, and the collection of consent might defeat the purpose of collecting the information
• To collect a debt
• To comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law or by any regulatory bodies having jurisdiction

Right to Withdraw Consent

Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent us from providing you, or continuing to provide you, with Abbella Financial Ltd.'s products and services or information that may be of value to you. You may also withdraw your consent as follows:

Your information may be made available by Abbella Financial Ltd. within the M3 Mortgage Group and to Authorized Agents or service providers to fulfill the purposes for which it has been collected or as set forth in this Privacy Policy. Abbella Financial Ltd. will not sell, rent or trade your personal information to any third party. However, we may share your personal information when authorized by law or as follows:

Abbella Financial Ltd. generally collects and uses personal information from or about its website visitors and users as follows:

Information You Provide

In many cases, we collect personal information directly from you when you visit or use our website. For instance, we may collect the following type of information:

Technical Information

When you visit our website, we may collect, using electronic means such as cookies, technical information. This information may include information about your visit to our website, including the IP address of your computer and which browser you used to view our website, your operating system, resolution of screen, location, language settings in browsers, the site you came from, keywords searched (if arriving from a search engine), the number of page views, information you entered, advertisements you have seen, etc.

Google Analytics

We use Google Analytics which allows us to see information on user website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page.

Google AdWords

We use Google AdWords Remarketing to advertise Abbella Financial Ltd. across the Internet and to advertise on third party websites (including Google) to previous visitors to our websites. AdWords remarketing will display ads to you based on what parts of the Abbella Financial Ltd. website you have viewed by placing a cookie on your web browser. This cookie does not in any way identify you or give access to your computer or mobile device. If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google's Ads Preferences Manager.

Third Party Advertising

We may use third-party advertising companies to collect data and/or serve ads when you visit our website. These companies may use information about your visits to our website and other websites in order to provide advertisements about goods and services of interest to you, at all times, in compliance with applicable privacy laws. You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Digital Advertising Alliance of Canada at: https://youradchoices.ca/

Your Choice with Cookies

You can block the use of cookies by activating the settings in your browser. The "Help" feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to withhold consent, or subsequently block cookies, you may not be able to access all or part of the content of our website.

Privacy Policies of Third Parties

This Privacy Policy only addresses the use and disclosure of information by Abbella Financial Ltd.. Other websites that may be accessible through Abbella Financial Ltd. websites have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.

In the event that you download and/or use any of our applications, we may require and collect, directly from you, information necessary to authenticate you. We may also record your IP geolocation, allowing us to block the access when the user is outside of Canada.

When you register on certain apps, you may be required to agree that we may send you notifications regarding your property evaluation, credit score, or general information by electronic messaging on a periodic basis. If you no longer want to receive any notifications, you can unsubscribe at any time.

Abbella Financial Ltd. strives to ensure that customers' personal information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is used. Abbella Financial Ltd. provides customer access to their personal information. Customers may correct or amend any inaccuracies in their personal information by contacting us using the contact information detailed in the section How to Contact Us of this Privacy Policy.

Abbella Financial Ltd. has the right to refuse a request for access to personal information if the information is protected by legal privilege, granting access would reveal confidential commercial information, the information was collected for purposes related to the detection and prevention of fraud, the information was generated in the course of a formal dispute resolution process, the information would likely reveal personal information about another individual, the request is vexatious or frivolous or any other reason, as authorized under applicable laws.

Personal Information Outside of Canada

In some cases, personal information that we manage may be transferred, processed and stored outside Canada, and therefore may be available to government authorities under lawful orders and laws applicable there.

Security of Personal Information

We will use reasonable security measures to protect your personal information against unauthorized access. Abbella Financial Ltd. has implemented security measures that contain administrative, technical and physical controls that are designed to safeguard your personal information. No method of transmission over the internet, or method of electronic storage, is 100% secure, however.

Retention

Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received or to satisfy legal requirements.

If you have questions, concerns or complaints regarding this Privacy Policy or the personal information that Abbella Financial Ltd. has about you, or to withdraw consent (when applicable) please contact:

Abbella Financial Ltd. will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. Our Privacy Policy may therefore change from time to time. We will post any privacy policy changes on our website and, if the changes are material, we will provide a more prominent notice.

Please note that both the English and French versions of our Privacy Policy have equal legal value.