Neighbourhood Holding Company Ltd. Privacy Policy

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Neighbourhood Holding Company Ltd. ("Neighbourhood") values and respects the privacy of its clients. This Privacy Policy informs you of Neighbourhood's privacy practices regarding its use of your personal information.

Contents of the Neighbourhood Privacy Policy:

1. Scope and Accountability

2. Collection, Use and Disclosure of Client Information and Personal Information

3. Retention and Security

4. Your Choices

5. Changes to this Privacy Policy

6. Contacting Us

1. Scope and Accountability

This Privacy Policy governs the collection, use and disclosure of personal information and client information (each as defined below) in connection with your relationship with Neighbourhood and your use of www.neighbourhoodholdings.com (the "Site"). This Privacy Policy does not apply to information that is not included in the definition of "personal information" in applicable privacy statutes.

All employees and those working on behalf of Neighbourhood are responsible for following this Privacy Policy. Neighbourhood will not sell your information to others. Neighbourhood also has a Privacy Officer who is responsible for overseeing Neighbourhood's compliance with this Privacy Policy.

Please see "Contacting Us" for information on how to contact Neighbourhood's Privacy Officer.

2. Collection, Use and Disclosure of Client Information and Personal Information

Collection

Client information means any data, including personal information, relating to you or your clients that is transmitted to Neighbourhood or that is stored with Neighbourhood or third parties engaged by Neighbourhood. Personal information means any information that may identify a person, such as a name, home address, telephone number, date of birth, e-mail address and social insurance number/social security number, among other things.

Neighbourhood will collect personal information that you provide when you apply for a mortgage.

Neighbourhood may also collect personal information during your visit to the Site through automatic data collection tools, which include web beacons, cookies, embedded web links, and other commonly used information-gathering tools. These tools collect certain standard information that your browser sends to its website such as your browser type and language and access times. They may also collect information about your internet protocol address and mac address.

Neighbourhood may also use some of these automatic data collection tools in connection with certain e-mails sent from Neighbourhood and therefore may collect information using these tools when you open the e-mail or click on a link contained in the e-mail.

We request a phone number and email address in case one of our representatives would need to reach you.

Uses

In addition to the specific purposes described above, certain uses of client information by Neighbourhood may be performed by Neighbourhood affiliates, service providers, agents and third parties as described below.

(1) Neighbourhood's Use of Client Information and Personal Information

Neighbourhood shall ensure that the use and disclosure of client information and personal information that it receives from you is limited to the purposes described in this Privacy Policy, your agreements with Neighbourhood, and as required by law.

Neighbourhood may also use client information and personal information to:

• enable us to provide our services to you;

• verify transactions you make and for billing, security, and authentication;

• analyze the Site, or the other services and information about our visitors and users, including research into our user demographics and user behaviour in order to improve our content and services;

• aggregate (non-identifiable) statistics about users of our services to prospective partners.

(2) Service Providers, Agents and Third Party Uses

Neighbourhood retains service providers, agents and suppliers to deliver products, services and other solutions. Neighbourhood policies require that service providers, agents and suppliers be required by contract to keep confidential the information received on behalf of Neighbourhood and not use or disclose it for any purpose other than to carry out the services they are performing for Neighbourhood.

(3) Foreign Service Providers, Agents and Third Parties

Some of Neighbourhood's service providers, agents and suppliers may be located outside of the country in which you are located. While personal information and client information will be subject to the laws of such jurisdictions, Neighbourhood's policies require that information processed, stored or used by service providers, agents and suppliers are always subject to the protections described in this Privacy Policy. Your personal information and client information will not be disclosed to third parties except with your consent or as set out in this Privacy Policy.

If you have any questions about the collection, use, disclosure or storage of personal information by service providers outside Canada please contact Neighbourhood's Privacy Officer as described below under "Contacting Us".

Disclosure of Personal Information

Neighbourhood will not sell, rent or lease your personal information or client information to third parties.

Except as described in this Privacy Policy, Neighbourhood will not disclose the client information personal information you provide to Neighbourhood to non-Neighbourhood affiliates, partners or third parties without your permission, unless to: (i) respond to duly authorized information requests of law enforcement and governmental authorities; (ii) comply with any law, regulation, subpoena or court order; (iii) help prevent fraud or to enforce or protect the rights and properties of Neighbourhood or its affiliates; (iv) protect the personal safety of Neighbourhood employees, customers or third parties; (v) assist in collecting any debt owed by you to Neighbourhood; or (vi) other such disclosures that are authorized, permitted or required under applicable law.

If all or part of Neighbourhood assets are sold or financed or if Neighbourhood were to merge with another company, client information and personal information in possession of Neighbourhood could be disclosed to the lender, buyer or merging entity, provided such client information and personal information were to be used in strict compliance with this Privacy Policy.

3. Retention and Security

Neighbourhood retains personal information and client information for as long as it is necessary to process related transactions, maintain appropriate financial and audit records, protect Neighbourhood's legitimate business interests and for as long as may be required by applicable laws.

All personal information and client information collected by Neighbourhood is protected by security measures appropriate to the sensitivity of the information.

4. Your Choices

How Neighbourhood Obtains Your Consent

You provide your express consent to the collection, use and disclosure of personal information and the use and disclosure of client information in accordance with this Privacy Policy when you voluntarily provide the requested information. You provide your implied consent to the use of automatic data collection tools by your continued use of the Site. In some instances, the law permits Neighbourhood to collect, use and disclose personal information obtained from public sources without your consent. If Neighbourhood obtains information from third parties other than such public sources, Neighbourhood requires those third parties to confirm that they have your consent to disclose your personal information for use by Neighbourhood.

Withdrawal of Consent

You have the right to withdraw your consent to the further collection, use and disclosure of your personal information and the use and disclosure of client information. If you request Neighbourhood to do so, Neighbourhood will take steps to destroy or delete client information and personal information that you have provided to us. Residual client information and personal information may remain in archived records or other historical records. In addition, Neighbourhood is not permitted to destroy business or accounting records of transactions that it is required to keep to: comply with statutory or other legal obligations and assert its legal rights. However, Neighbourhood will not use client information or personal information for other commercial purposes once you withdraw your consent.

You may withdraw your consent to the use of automatic data collection tools by managing your privacy settings on your computer, your web browser and any privacy or security software that you operate on your computer. For more information please see the instructions that accompany your computer, web browser and privacy or security software.

If you have any questions about the withdrawal of consent to online collection of personal information, you may submit a written request to Neighbourhood's Privacy Officer at the address set out below under "Contacting Us".

When submitting a request, you will be asked to provide suitable identification or to otherwise identify yourself.

Individual Access to and Correction of Personal Information

Neighbourhood strives to keep accurate information by using technology and management processes and policies. Upon receipt of a written request Neighbourhood will provide you with reasonable access to the client information and personal information you provided to Neighbourhood as well as the ability to correct the information, if necessary.

To protect your privacy and security, Neighbourhood will also take reasonable steps to verify your identity before releasing any information to a requesting party and before any corrections will be made. Neighbourhood reserves the right to request appropriate proof of the requested corrections.

To access the personal information provided to Neighbourhood an individual must submit their request in writing to the address set out below under "Contacting Us".

Neighbourhood will refer to you any requests that we may receive for access to client information held by us on your behalf. We will also assist you wherever possible in responding to any access requests you may receive.

5. Changes to This Policy

Neighbourhood may revise this Privacy Policy from time to time. If Neighbourhood revises this Privacy Policy, Neighbourhood will post the revised Privacy Policy in its entirety on http://www.neighbourhoodholdings.com/s/Privacy-Policy with an updated revision date.

Neighbourhood may also notify you by other means such as sending an e-mail or posting a notice on the home page.

6. Contacting Us

Neighbourhood values your opinions. If you have a privacy inquiry, compliment or complaint, you may contact the Neighbourhood Privacy Officer by submitting an electronic request via www.neighbourhoodholdings.com or a written request to:

Neighbourhood Holdings Company Ltd.

Attn: Neighbourhood Privacy Officer

380, 1050 Homer Street

Vancouver, BC V6B 2W9

 

Last Updated: February 17, 2017