This Privacy Policy describes the policies and procedures of Capitis Private Mortgage Investment Corp. on the collection, use, and disclosure of Your personal information when You use the Service. It also outlines Your privacy rights under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and how the law protects You.

We use Your Personal Data to provide and improve the Service, including the facilitation of private mortgage loan applications and connections between Borrowers and Investors. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy has been created with the assistance of an online generator but has been tailored to the specific business operations of the Company.

INTERPRETATION AND DEFINITIONS

INTERPRETATION

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

DEFINITIONS

For the purposes of this Privacy Policy:

• Borrower: Any person, persons, or business entity that registers on the Service to apply for a loan.
• Company: (referred to as either "the Company," "We," "Us" or "Our" in this Agreement) refers to Capitis Private Mortgage Investment Corp., 9-2020 Lanthier Drive, Ottawa, Ontario, K4A3V4.
• Cookies: Small files that are placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country: Refers to Canada, and specifically the Province of Ontario.
• Financial Data: Any sensitive financial information collected from You, including but not limited to loan amount requests, property values, and other information necessary for loan underwriting.
• Investor: Any person, persons, or business entity that registers on the Service to provide funding for loans.
• Personal Data: Any information that relates to an identified or identifiable individual, including contact information and Financial Data.
• Service: Refers to the entire suite of services provided by the Company, including but not limited to the loan application portal, underwriting services, and the facilitation of connections between Borrowers and Investors.
• Service Provider: Any natural or legal person who processes data on behalf of the Company. This includes third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.
• Usage Data: Data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website: Refers to Capitismic.com, accessible from https://capitismic.com.
• You: Means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

COLLECTING AND USING YOUR PERSONAL DATA

TYPES OF DATA COLLECTED

PERSONAL DATA

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Contact Information: Email address, first name and last name, phone number, and mailing address.
• Financial and Property Data (from Borrowers): This includes information collected via our loan application surveys, such as the requested loan amount, the purpose of the loan, the type of loan, the address of the subject property, and its approximate value.
• Investor Information: Data required to qualify You as an Investor, which may include information related to your accreditation status and other financial details.

USAGE DATA

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g., IP address), which we collect for security and rate-limiting purposes, browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

SMS MESSAGING & COMPLIANCE

Text Message Program Terms & Conditions - By opting into our SMS messaging services, you agree to receive text messages related to our services, including appointment reminders, customer support, and important updates.

Opt-In & Consent:

• You will only receive messages if you have explicitly opted in.
• We maintain timestamped records of all opt-in actions.
• We comply with the Telephone Consumer Protection Act (TCPA) and all applicable laws.

Opt-Out Instructions:

• You can cancel SMS notifications at any time by replying "STOP".
• We will send a final confirmation message, and no further messages will be sent unless you re-opt in.
• All opt-out requests are processed immediately.

Message Frequency & Content:

• Message frequency varies based on your interactions with our business.
• Messages will be directly related to the services you have requested.
• We do not send promotional content without specific consent.

Carrier Information:

• Standard message and data rates may apply.
• Carriers are not liable for delayed or undelivered messages.

TRACKING TECHNOLOGIES AND COOKIES

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features.
• Cookies Policy / Notice Acceptance Cookies: These Cookies identify if users have accepted the use of cookies on the Website.
• Functionality Cookies: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference.
• Third-Party Tracking Cookies: These cookies and pixels are placed by third-party services such as Google and Facebook to help Us analyze and monitor the effectiveness of our marketing and advertising campaigns.

ADVERTISING, ANALYTICS AND REMARKETING

We may use third-party advertising and analytics services, including but not limited to Meta Platforms Inc. (Facebook and Instagram), Google LLC (including Google Ads and Google Analytics), and other advertising partners, to measure the effectiveness of Our marketing campaigns and to deliver advertisements that may be relevant to You.

These third parties may use cookies, pixels, web beacons, and similar technologies to collect or receive information from Our Website and elsewhere on the Internet and use that information to provide measurement services, analytics, advertising attribution, and targeted advertising. This information may include Your Internet Protocol (IP) address, browser type, device identifiers, pages visited, time spent on pages, and other interaction data.

We use this information to better understand how users interact with Our Website, improve Our Service, evaluate the effectiveness of Our advertising campaigns, and deliver more relevant advertisements to users who may be interested in Our services.

You may control how Your information is used for advertising purposes by adjusting Your browser settings, managing Your cookie preferences, or visiting the following third-party privacy and advertising settings:

• Google Ads Settings: https://adssettings.google.com
• Meta Privacy Policy: https://www.facebook.com/privacy/policy/

By using Our Service, You consent to the use of Cookies and other tracking technologies as described in this section. You may disable Cookies through Your browser settings; however, doing so may affect the functionality and availability of certain features of Our Service.

USE OF YOUR PERSONAL DATA

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service: including to monitor the usage of our Service, manage Your Account, and verify Your identity.
• For Loan Facilitation: to process, evaluate, and underwrite loan applications; to manage the administration of funded loans; and to comply with regulatory requirements for Mortgage Investment Corporations.
• To contact You: to contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication for updates or communications related to the Service, including security updates and information about Your loan application.
• For Marketing and Promotion: to provide You with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already enquired about, unless You have opted not to receive such information. (We do not sell, rent, or trade your mobile phone number or SMS consent to third parties for their marketing purposes).
• To manage Your requests: to attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, or other sale or transfer of some or all of Our assets, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other business purposes: We may use Your information for other business purposes, such as data analysis, identifying usage trends, and to evaluate and improve our Service, marketing, and your experience.

RETENTION OF YOUR PERSONAL DATA

The Company will retain Your Personal Data only for as long as is necessary for the purposes for which it was collected, as outlined in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

TRANSFER OF YOUR PERSONAL DATA

Your Personal Data is processed at the Company's operating offices in Ottawa, Ontario, Canada, and in any other places where the parties involved in the processing are located. This means that your information may be transferred to—and maintained on—computers located outside of Your province or country where the data protection laws may differ from those in Your jurisdiction.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and that no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of Your data and other personal information.

ACCESS TO AND DELETION OF YOUR PERSONAL DATA

You have the right to access, delete, or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us directly to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or a lawful basis to do so. We will notify You of the reasons for any refusal to grant an access or deletion request.

DISCLOSURE OF YOUR PERSONAL DATA

The Company may disclose Your Personal Data in the following situations:

• With Service Providers: We may share Your personal information with Service Providers, such as credit bureaus, appraisal management companies, legal counsel, and analytics providers, to conduct due diligence, underwrite your loan, manage the mortgage, and to contact You.
• For Business Transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company. (Note: In such cases, your text messaging opt-in data remains protected under the terms of this policy).
• With Your Consent:We may disclose Your personal information for any other purpose with Your consent.

SMS DATA PROTECTION STATEMENT (STRICT NON-SHARING POLICY) Notwithstanding any other provision in this policy, the following applies to your mobile information:

No mobile information will be shared with third parties/affiliates for marketing and/or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

RIGHT TO ACCESS AND CORRECT

You have the right to request access to the personal information we hold about you and to challenge the accuracy and completeness of that information. Upon request, we will provide you with a copy of your personal information and will correct any inaccuracies.

SECURITY OF YOUR PERSONAL DATA

The security of Your Personal Data is very important to Us. While We strive to use commercially acceptable means to protect Your Personal Data, including organizational, technical, and physical safeguards, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we endeavor to protect Your Personal Data, We cannot guarantee its absolute security.

DATA BREACH PROTOCOL

In the event of a data breach involving your personal information, the Company will promptly take steps to contain the breach and notify you and the Privacy Commissioner of Canada if there is a real risk of significant harm. We will also investigate the breach and take steps to prevent future incidents.

CHILDREN'S PRIVACY

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We will take steps to remove that information from Our servers.

LINKS TO OTHER WEBSITES

Our Service may contain links to other websites that are not operated by Us, such as third-party service providers. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

ACCOUNTABILITY

The Company is responsible for all personal information under its control. We have designated a Privacy Officer who is accountable for our compliance with this Privacy Policy and PIPEDA. The contact information for our Privacy Officer is provided in the "Contact Us" section.

CHANGES TO THIS PRIVACY POLICY

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

If you have any questions about this Privacy Policy, You can contact us:

• By email: info@capitismic.com
• By mail: Capitis Private Mortgage Investment Corp., 9-2020 Lanthier Drive, Ottawa, Ontario, K4A3V4

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