BrokerMate Privacy Policy

1. Who we are and what this policy covers

BrokerMate is operated by MEERKATS DEV INC., Vancouver, British Columbia, Canada (“BrokerMate”, “we”, “us”). This policy explains how we collect, use, share and protect personal information about:

• Brokers: mortgage professionals and their staff who subscribe to BrokerMate (“customers”);
• Borrowers: people a broker invites to submit documents through BrokerMate;
• Visitors: people who visit thebrokermate.com.

We follow Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and, where they apply, British Columbia’s and Alberta’s Personal Information Protection Act and Quebec’s Act respecting the protection of personal information in the private sector (as amended by Law 25).

2. Our role

• For broker account, billing and website information, we decide how it is used and are responsible for it.
• For borrower information, the broker you are working with decides why it is collected and is responsible for it. We process it on the broker’s behalf and under their instructions, only to provide the BrokerMate service to them. If you are a borrower, your broker’s own privacy policy also applies to you.

3. Information we collect

Brokers: name, business email and phone, brokerage name, profile photo and branding, account and sign-in information, billing details (handled by our payment processor; we don’t store full card numbers), support messages, and credentials you give us to connect services such as Finmo.

Borrowers: the information and documents you choose to submit to your broker through BrokerMate. This includes your name, email and (if you give it) phone number, what the mortgage is for, your income sources, any notes you add, and your documents. Depending on what your broker asks for, documents can include identity documents, employment and income documents (such as pay stubs, T4s, notices of assessment and employment letters), bank and account statements, property documents, and details about your debts and assets. Some of these documents can contain your Social Insurance Number or date of birth; only submit what your broker has asked for.

Visitors: when you visit thebrokermate.com, our hosting provider (Cloudflare) processes basic technical information such as your IP address, browser type, the pages you request and the time, to deliver the site and protect it from abuse. The website doesn’t use analytics tools or cookies. If you contact us through the website’s form, we collect what you send: your name, work email, brokerage, the plan you’re asking about and your message.

4. How we use information

We use personal information only to:

• provide the service: collect documents for your broker, read them to recognize each document and sort it into your broker’s checklist, notify your broker, and send information to systems your broker connects (such as Finmo) when your broker chooses to;
• run broker accounts, billing and support;
• keep the service secure, prevent fraud and abuse, and fix problems;
• meet our legal obligations.

We use personal information for a new purpose only with consent, unless the law allows otherwise.

5. What we never do

• We never sell personal information.
• We never use borrower information for advertising or marketing.
• We never use borrower information to train AI models, and [ONLY IF TRUE FROM STEP 1: our AI provider is contractually not allowed to use it to train theirs].
• We don’t put sensitive information (such as SIN, income or account numbers) in web addresses, and we work to keep it out of logs.
• We don’t access a borrower’s documents except to provide, support or secure the service for the broker, or when the law requires it.

6. Consent

Brokers are responsible for obtaining borrowers’ consent, and giving any notice the law requires, before asking them to submit information through BrokerMate. By submitting documents, a borrower agrees that their broker, and BrokerMate on the broker’s behalf, may use them for the purposes in section 4. You can withdraw consent at any time by contacting your broker (or us, and we’ll pass it on), subject to legal and contractual limits; this may mean your broker can’t continue processing your application through BrokerMate.

7. Automated document processing

BrokerMate uses automated tools, including artificial intelligence provided by Anthropic (Claude), to read submitted documents as they are uploaded, recognize what kind of document each one is and whose it is, and sort it into your broker’s checklist. These tools can make mistakes, and you can move a file to the right item before you submit. BrokerMate does not make decisions about you. Your broker reviews your documents, and any decision about a mortgage is made by your broker and lender, not by BrokerMate. You can ask your broker what information was used and have it corrected.

8. Who we share information with

We share personal information only with:

• Service providers (sub-processors) that help us run BrokerMate, under agreements that limit their use of the information to providing services to us and require them to protect it:

• Systems your broker chooses to connect, such as Finmo, when your broker sends a file there. Those services have their own privacy policies.
• Authorities or others when the law requires it, for example under a court order, or to protect someone’s safety.
• A buyer or successor if BrokerMate is sold or merged, under the same protections as this policy.

9. Where information is stored

We haven’t confirmed that any of our service providers store or process information in Canada. They may store or process it outside Canada, including in the United States. When that happens, the information is subject to the laws of that country, and authorities there may be able to access it under those laws. We choose providers that protect information to a standard comparable to Canadian law. [If data is moved to Canadian regions later, update this section and the “Last updated” date.]

10. How we protect information

We use administrative, technical and physical safeguards suited to how sensitive the information is. These include encryption in transit (HTTPS) between your browser and BrokerMate, and between our servers and our database; encryption of stored Finmo credentials and of submissions we hold temporarily when delivery is delayed; keeping each broker’s data separate; sign-in links that expire (after 20 minutes for everyday sign-in) and sessions that expire after 30 days; masking of email addresses and similar identifiers in our logs; and a record of when submissions are received and documents are downloaded. No system is completely secure. Brokers are responsible for keeping their own logins and devices secure.

11. How long we keep information

• Borrower documents and the details submitted with them: kept in document storage until they are deleted. There is no automatic deletion today. Documents delivered to a broker are kept in that broker’s own storage for as long as the broker decides; we keep no copy of them, unless the law requires us to keep them longer.
• If a submission can’t be delivered to storage right away, we hold an encrypted copy for up to 7 days and delete it once it is delivered or the 7 days are up.
• The AI’s reading of each document isn’t stored; only the checklist item each file ends up in is saved with the submission.
• Broker account information: while the subscription is active, then exported on request for 30 days and deleted within 30 days after that.
• Records of received submissions and document downloads: while the broker’s subscription is active, then deleted within 30 days after it ends.
• Billing records: as long as tax law requires.
• When we no longer need information, we delete or anonymize it securely. [DESCRIBE THE DELETION PROCESS ONCE IT EXISTS.]

Brokers should keep their own copies of anything they are legally required to retain (for example, under anti-money-laundering rules); BrokerMate is not a record-keeping system for those obligations.

12. Your rights

Subject to the law, you can:

• ask whether we hold personal information about you and get a copy;
• ask us to correct information that’s inaccurate or incomplete;
• withdraw your consent (see section 6);
• ask us to delete information we no longer need;
• in Quebec, ask for your information in a structured, commonly used technology format.

We reply within 30 days. We may need to confirm your identity first, and we’ll explain any reason we can’t fully meet a request.

13. If you’re a borrower

Because your broker controls your information, we’ll usually pass your request to your broker and help them respond. You can also contact your broker directly.

14. Privacy incidents

If a privacy breach involving personal information we hold creates a real risk of significant harm, we will notify affected brokers without undue delay, notify the Office of the Privacy Commissioner of Canada and other regulators as the law requires, and help brokers notify affected borrowers. We keep a record of all privacy incidents. [CONFIRM THIS PROCESS EXISTS.]

15. Cookies and analytics

Our website doesn’t use advertising, analytics or tracking cookies, and doesn’t set cookies at all. Its fonts are served from our own site.

The BrokerMate app sets one cookie, which keeps brokers signed in for up to 30 days. It doesn’t set cookies on the borrower upload page; that page remembers your language choice in your browser’s storage, which you can clear in your browser settings. The app loads its fonts from Google Fonts, so Google receives your IP address and browser details when you open it.

16. Children

BrokerMate is not intended for anyone under the age of majority in their province, and we don’t knowingly collect their information.

17. Changes to this policy

We’ll post any changes here and update the “Last updated” date. If a change is significant, we’ll email brokers at least [30] days before it takes effect.

18. Contact us and complaints

Our Privacy Officer is responsible for how we handle personal information:
Arash Zare, President, MEERKATS DEV INC., Vancouver, British Columbia, Canada, info@thebrokermate.com.

If you’re not satisfied with our response, you can contact the Office of the Privacy Commissioner of Canada (priv.gc.ca), the Office of the Information and Privacy Commissioner for British Columbia (oipc.bc.ca), the Office of the Information and Privacy Commissioner of Alberta (oipc.ab.ca), or the Commission d’accès à l’information du Québec (cai.gouv.qc.ca), depending on where you live.