Your privacy matters. This policy explains how we collect, use, disclose, and protect personal information in our mortgage brokering activities.
Who we are
Sukru Akyuz, Mortgage Agent Level 1 (FSRA Licence No. M24003381), operating under Kingsdale Mortgage Centre, (FSRA Brokerage Licence No. 13585, the “Brokerage”). “We”, “us”, and “our” refer to the Brokerage and its agents providing mortgage services to you in Ontario.
Scope
This policy applies to our commercial activities, websites (including www.sukru.ca), forms, emails, SMS/WhatsApp, and in-person interactions related to mortgage advice, applications, and placement.
Legal basis and principles
- PIPEDA applies to private-sector organizations in Canada. We follow its 10 Fair Information Principles including accountability, identifying purposes, consent, limiting collection, limiting use/disclosure/retention, accuracy, safeguards, openness, individual access, and challenging compliance.
- CASL requires consent to send commercial electronic messages and clear unsubscribe options.
- PCMLTFA/FINTRAC requires client identification, record-keeping, and reporting for anti-money-laundering compliance in the mortgage sector.
What we collect
We collect information needed to provide mortgage brokering services and comply with law, for example:
- Identity and contact: name, address, phone, email, date of birth, government-issued ID details.
- Financial: income, employment, assets, liabilities, banking and payment info.
- Credit and risk: credit reports/scores, obligations, payment history.
- Property and mortgage details: property address, value, insurance, appraisals.
- Sensitive fields you choose to provide that are relevant to underwriting decisions.
- Website/technical: IP address, device/browser data, cookies or similar for security and analytics.
Where it comes from
- You, via forms, calls, meetings, email, SMS, and messaging apps.
- Third parties you authorize: credit bureaus, employers, appraisers, insurers, lenders, and other financial institutions.
- Regulatory and fraud-prevention sources required by law.
How we use information
- To assess suitability and arrange a mortgage or related products and services you request.
- To verify identity, prevent fraud, and meet AML/ATF obligations.
- To obtain credit reports and share application packages with potential lenders/insurers.
- To communicate about your application and our services. Marketing emails or texts only with consent; you may unsubscribe at any time.
- To operate and secure our website and systems.
Consent
We obtain consent before collecting, using, or disclosing personal information, except where permitted or required by law. You may withdraw consent at any time; doing so may limit our ability to provide services or proceed with an application.
Note on SIN: providing a SIN is optional but may help match your credit file. If you decline, we may still obtain your credit report using other identifiers.
Sharing your information
- Lenders, mortgage insurers, and service providers involved in underwriting, funding, and administering a mortgage.
- Credit bureaus to obtain or update credit information.
- Compliance service providers, auditors, legal counsel, IT and cloud vendors under confidentiality and security obligations.
- Regulators or law enforcement when required by law.
Cross-border transfers
Some service providers may store or access data outside Canada. Foreign laws may allow authorities access to your information. We use contractual safeguards and expect comparable protection.
Retention and destruction
We retain personal information only as long as necessary for the identified purposes, to meet legal, regulatory, tax, audit, and AML/ATF record-keeping obligations, and for reasonable limitation periods. When no longer needed, data is securely destroyed or anonymized.
Accuracy
We rely on you to provide accurate and complete information and to update us if details change.
Safeguards
- Administrative: access controls, staff training, policies and procedures.
- Technical: encryption in transit and at rest where appropriate, multi-factor access, secure backups, monitoring.
- Physical: restricted office and device security.
Privacy breaches
We assess and document all security incidents. If a breach creates a real risk of significant harm, we notify affected individuals and report to the Office of the Privacy Commissioner of Canada as required, and we keep records of all breaches.
Your choices and rights
- Access and correction: You may request access to the personal information we hold and request corrections.
- Withdraw consent: You may withdraw consent for non-essential uses or marketing.
- Unsubscribe: Every marketing message includes an unsubscribe option per CASL.
Cookies and analytics
We may use cookies or similar technologies for functionality, security, and analytics. You can adjust browser settings to limit cookies; some features may not work as intended.
Children’s privacy
Our services are not directed to children under 13. We do not knowingly collect personal information from children without parental consent.
Third-party links
Our site may link to third-party websites we do not control. Their privacy practices apply to their sites.
How to contact me
Privacy Officer
Email: mortgage@sukru.ca
Complaints
If you have a privacy concern, contact our Privacy Officer. If your concern is not resolved, you may contact the Office of the Privacy Commissioner of Canada (priv.gc.ca) or the appropriate provincial authority.
Updates to this policy
We may update this policy. The effective date above shows the latest revision. Material changes will be highlighted on this page.
This policy summarizes how we apply PIPEDA and related obligations in a mortgage-brokering context. Copies of our detailed procedures are available on request.
