Vector Management Limited
Vector Financial Services Limited


“Act”. Canada’s Personal Information Protection and Electronic Documents Act
“Borrower”. A Borrower is an individual or a corporation, which has entered into or is contemplating entering into an arrangement to borrow funds from Vector in the form of a syndicated mortgage. A Guarantor is considered to be a Borrower for the purposes of this document.

“Client”. Any person or entity that has entered into, or is contemplating entering into, a business arrangement (ie. borrowing, lending, leasing, etc.) with Vector.

“Investor”. An Investor is an individual or a corporation that lends money through a Vector arranged mortgage to a Borrower. “Personal Information”. Any information that distinctively refers to individual Clients, such as their name, address, birth date, sex, email address, Social Insurance Number, bank account information, etc.

“Vector”. Vector Management Limited, Vector Financial Services Limited and all companies, which are affiliated, associated, or managed by them.

Vector pledges to protect our Clients’ right to privacy under Canada’s Personal Information Protection and Electronic Documents Act (“Act”). We will safeguard any Personal Information which we may have during our business. Details about our policy and our Clients’ rights are outlined below:

Protection of Information
1. EMPLOYEES – All of Vector’s employees are aware of the Act and have been given a copy of Vector’s Privacy Policy. Each employee has signed an agreement to abide by the policies therein (see Appendix “A” for a copy of this agreement)
2. ELECTRONIC – Vector uses electronic safeguards such as firewalls and security software to protect online Personal Information from hacking or unauthorized computer access. Additionally, all computer stations require a password to access them.
3. PHYSICAL – Vector’s offices are secured and alarmed after hours. Hard-copy documents are filed away out of sight. Once business with a client is concluded and the superfluous documents no longer needed, or required to be retained by Government Agencies such as Canada Revenue Agency, they are destroyed by means of shredding.

Sharing of Information
There are times, during business, where it may be necessary to share some of the Clients’ Personal Information with third parties. This is particularly so where Clients apply for loans. Vector’s Loan Proposal Documents alert clients to the eventuality that some of the Clients’ credit information may be shared with third parties. By signing and accepting Vector’s Loan Proposal and Commitment Letter, Clients consent to Vector sharing credit information with third parties.

In some cases, Vector may have to disclose some Clients’ Personal Information to financial institutions, government agencies, legal and accounting professionals, or law enforcement agencies. Vector will cooperate and disclose such if required by law, and then only disclosing the information specifically requested and permitted by the Act.

Notwithstanding the above, Clients’ personal information will never be used nor sold for marketing or any other purposes.

Borrowers consent to Vector’s use of the personal information provided to ascertain your credit-worthiness as a Borrower and/or Guarantor. This may include, but is not limited to, obtaining credit reports, contacting your bank, verifying your employment, etc. The funds advanced under this mortgage may be syndicated and come from a number of private lenders who will each contribute a portion of a loan. The Ontario government’s Mortgage Brokerages, Lenders and Administrators Act requires that lenders have access to financial information about the Borrower’s ability to meet mortgage payments. This information is provided in the required Investor/Lender Disclosure Statement for Brokered Transactions which all lenders in this loan will receive. All of our Investors/Lenders have been made aware of the Act and will have signed a document agreeing to be bound by the Act and keeping any Borrower’s personal information in strict confidence.

Investors who participate in Vector’s loans will have access to certain financial information about the Borrower as required by the Mortgage Brokerages, Lenders and Administrators Act. All Investors have agreed to fully abide by the Act by signing a document attesting to that fact.

The Investor name (either corporation name or personal name) and amount loaned by each Investor participating in a particular Vector loan will not be seen by other Investors in that particular loan. Additionally, group emails will be sent “BCC” (where all email address are hidden from view) to protect the privacy of our Investor.

Clients should be aware that Vector’s primary means of communication with Clients is via email. Email communications are not completely secure. It is possible, however unlikely, that a third party could intercept these messages. In light of this, Vector strictly limits the amount of personal information contained in an email. Vector will never send highly sensitive information such as bank account information or a social insurance number via email.

For Investors, an email may contain Personal Information such as an Investor’s email address, home or business address, and the amount invested in a particular loan or the amount of a loan interest or principal distribution.

For Borrowers, an email may contain Personal Information such as an Investor’s email address or home or business address. Additionally, communications such as commitment letters and loan agreements are often sent via email as attachments. These documents may contain such Personal Information as a Borrower’s or Guarantor’s name, corporate name, address, and loan details such as property address, property legal description, and the amount to be borrowed.

Retention of Personal Information
Personal information will generally be kept for a minimum of seven years after the conclusion of any business relationship as per Canada Revenue Agency guidelines.

Bank Accounts
A limited number of Clients have chosen to have certain bank accounts administered by Vector. A weekly report, generated by the CIBC, containing all Vector administered bank accounts at the CIBC, including account names (either personal name or corporate name), account numbers, and their corresponding balances are circulated to inside Investors within Vector’s offices. Clients who have provided banking information to Vector for the purposes of direct deposits of monthly mortgage interest payments and principal repayments are not included in this report.

Vector’s Website
No personal information is collected about you while browsing Vector’s website. The website does not use cookies nor any other methods to identify, track, or remember anything about visitors have viewed the website. No personal information is made available on Vector’s website.

Access to Your Personal Information
Clients have the right to know exactly what Personal Information Vector has about them. If requested in writing directly by Clients, Vector will make such information available in a timely fashion.

Any questions you have may be directed to our Chief Privacy Officer, Richard Cohen, by phone at 416-483-8018 ext. 231 or in writing to:

Vector Management Limited
25 Imperial Street, Suite 500
Toronto, Ontario, M5P 1B9

Attn: Privacy Officer