Privacy policy

Who this policy covers

This policy applies to 360 Lending Solutions, a mortgage brokerage licensed by the Financial Services Regulatory Authority of Ontario under Brokerage Licence #12448, operating the trade name Reverse Mortgages of Canada and the website reversemortgagesofcanada.com.

It explains how we handle personal information under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and how we handle commercial electronic messages under Canada's Anti-Spam Legislation (CASL).

What we collect, and when

Through the estimator on this site, only what you type into it: your name, email address and telephone number, together with the property details you provide for the estimate, being the age of the youngest homeowner, whether there are one or two homeowners, an estimated home value, the property type and the general area.

We also record the date and time of your submission, the wording of the consent you agreed to, and the page you submitted from. That record exists because CASL requires us to be able to prove consent.

If you telephone us, we collect what you tell us. If you go on to apply for a mortgage, we will collect considerably more, and you will be given a separate and more detailed consent at that point.

The estimator itself does not identify you. You can move the sliders and see a range without entering any contact details at all.

Why we collect it

To respond to your enquiry, to prepare a more accurate estimate than the website can produce, and to advise you on whether a reverse mortgage suits your circumstances. If you proceed, to arrange a mortgage on your behalf and to meet our obligations as a licensed brokerage.

We do not sell your personal information. We do not rent it, trade it, or pass it to third parties for their own marketing purposes.

Consent, and how to withdraw it

We collect your contact details only when you tick the consent box and submit the form. That consent covers contacting you about the enquiry you made.

You may withdraw consent at any time. Email us, or reply to any message we send you, and say so. We will stop contacting you and confirm that we have. Some records may be retained after withdrawal where law or our regulatory obligations require it.

Who we share it with

We use third party service providers to operate the business, and your information passes through them. Specifically, a customer relationship management system to record and manage enquiries, and an email service to send and receive messages. These providers act on our instructions and are not permitted to use your information for their own purposes.

If you choose to proceed with an application, we disclose the information necessary to arrange the mortgage to the lender or lenders we submit your file to, to an appraiser, and to the lawyers involved in completing the transaction. We will tell you which lender before we submit anything.

We may also disclose information where we are required to by law, by a court, or by FSRA in the course of its supervision of licensed brokerages.

Some service providers store data outside Canada, which means your information may be subject to the laws of another jurisdiction, including lawful access requests by authorities there. If this concerns you, contact us and we will tell you what we can about where your information sits.

How long we keep it

Enquiries that do not proceed are retained only as long as needed to deal with the enquiry and to evidence the consent we relied on, then deleted.

Where a mortgage is arranged, we are required by the Mortgage Brokerages, Lenders and Administrators Act, 2006 and its regulations to retain the file for a prescribed period after the transaction. Those records are kept for that period and then destroyed.

How we protect it

The site is served over HTTPS, so what you type into the form is encrypted in transit. Credentials for our systems are stored outside the public area of the web server. Access to enquiry records is limited to the people at the brokerage who need it to do their work.

No system is perfect and we will not pretend otherwise. If a breach occurred that created a real risk of significant harm to you, we would notify you and the Office of the Privacy Commissioner of Canada, as PIPEDA requires.

Cookies and website analytics

We use Google Analytics to understand how people find and use the site, in aggregate. It sets cookies and collects a truncated IP address, the pages you viewed, and general location at the level of city or region. We use it to see which pages are useful, not to identify you.

We also use Google Ads conversion tracking, which records that a form submission or a telephone call came from an advertisement. If you click one of our ads, the telephone number displayed may be a tracking number that forwards to our main line.

You can block cookies in your browser settings, or install Google's Analytics opt-out add-on. The site works normally either way.

Your right to see what we hold

You may ask us what personal information we hold about you, what we have used it for, and who we have disclosed it to. You may ask us to correct anything inaccurate. There is no charge and we will respond within thirty days.

To make a request, or to ask anything about this policy, write to the privacy contact at 360 Lending Solutions, 2175 Sheppard Avenue East, Suite 307, Toronto, Ontario, M2J 1W8, or telephone 1-416-878-9448.

If you are not satisfied with how we have handled a privacy matter, you may complain to the Office of the Privacy Commissioner of Canada. For complaints about our conduct as a brokerage, see our complaints policy.

Changes to this policy

If we change how we handle personal information we will update this page and change the date below. Material changes affecting information we already hold will be brought to your attention directly.