The Home Equity Partners Inc. and its affiliates and related entities (“HEQ Partners”, “we”, “us” or “our”) are committed to respecting your privacy and protecting the personal information we collect, use, and disclose in the course of our business, in accordance with applicable laws and regulations.

This privacy policy (“Privacy Policy”) describes our privacy practices, including:

• How we manage personal information and safeguard the privacy of our customers and those individuals who provide us with personal information (“you” or “your”) when accessing and obtaining our products or services and/or accessing or using our website, found at www.theheqpartners.com (our “Website”).
• The types of personal information we collect about you, why we collect it, how we use it, how we protect it and under what circumstances we share it with third parties. This Privacy Policy also describes your rights related to your personal information and the decisions you can make about your personal information with respect to us.

Know what you’re looking for? Navigate to any section of our Privacy Policy using the links below:

This policy applies to information we collect, use, or disclose about you in any manner, including on our Website or by email, text, and other electronic messages.

Please read this Privacy Policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, please do not use our Website. By submitting your personal information to HEQ Partners or by otherwise accessing or using our Website, you indicate that you understand, accept, and consent to the practices described in this Privacy Policy.

We reserve the right to amend this Privacy Policy at any time by posting a revised version on our Website. We recommend that you check our Website periodically in order to review our current Privacy Policy. You can tell if this Privacy Policy has changed by checking the effective date that appears at the top of this Privacy Policy. If you have an account with us, we may notify you via email if we consider changes to this Privacy Policy to be significant. If you continue to access or use our Website or our products or services after this Privacy Policy has changed or notice of the change has been given, you are deemed to have accepted such changes.

This Privacy Policy should be read in conjunction with our Website Terms of Use

HEQ Partners will only collect, use or disclose personal information in accordance with applicable laws and regulations and this Privacy Policy. We obtain consent before we collect, use or disclose your personal information for certain identified purposes. We will normally request your consent in writing at the time of collection, however, we may accept your oral consent or imply your consent through your conduct with us and/or your acceptance of our products or services in certain instances.

Subject to the legal and contractual obligations between HEQ Partners and you and reasonable notice from you, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting us. The period of reasonable notice will vary depending on the nature of the information and its purpose. There is no obligation on HEQ Partners to cease any use or retract any disclosure made prior thereto.

If you provide HEQ Partners or its service providers with personal information of another individual, you represent and warrant that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

HEQ Partners collects personal information by lawful means. We may collect the following information from you in the following contexts:

Information You Provide to Us

When you provide your personal information to us for any purpose such as accessing our products or services, creating an account with us, submitting an application, or entering into a Home Equity Sharing Agreement (“HESA”), uploading or submitting information through our Website or contacting us to obtain our products or services, you may voluntarily provide us with certain types of personal information, such as:

• general information such as your first and last name, postal address, phone number, date of birth, gender, e-mail address, driver’s license information, account credentials and social insurance number;
• property information such as your home’s address, bills and statements relating to your property and the identities of co-owners, if any;
• financial information such as your direct deposit information, annual income (and applicable documents substantiating same), and the details of any debts or guarantees secured by your home; and
• employment information such as your employment status, and the identity of your employer, the title of your role and your salary, as applicable.

Third Party Providers

Credit Reporting Agencies: Depending on your interactions with us and your use of our products and services, such as if you make an application, we may obtain, and continue to periodically obtain, your credit score, credit reports, and other relevant information from a credit reporting agency. This information will only be obtained to process a transaction, facilitate a HESA, provide our products or services to you or to act in accordance with any agreement between you and HEQ Partners.

Financial Institutions: We may collect personal information from institutions that offer financial products or services to consumers, such as insurance brokers, and others that have obtained your consent to disclose such information to us. Such financial institutions may include banks, mortgage lenders, loan brokers, financial or investment advisors, insurance companies and debt collectors.

ID Verification Services: We may verify your identity using third party service providers.

Automated Data Collection

Our Website may use cookies to analyze our traffic. Cookies enable us to track and target the interests of our users to enhance the experience on our Website. This information is not personally identifiable on its own and can be used for aggregate website traffic and trend analysis. Such information may include domain names and internet protocol (IP) addresses, usage statistics (e.g., types of web browsers and operating systems used) and browsing history.

Electronic Communications and Support Services

If you e-mail, write to us, or otherwise contact us and provide us with your contact information (e.g., your name, account details, e-mail address, mailing address), we may collect the information that you provide to us to communicate with you through electronic means, such as by sending you emails.

HEQ Partners collects, uses and discloses your personal information for the purposes identified at the time of or before collection, or as otherwise permitted or required by applicable law, including, as applicable, for the following purposes:

• To provide you with our products or services and to facilitate entering into a HESA or transaction that you may choose to enter into.
• To identify and verify you, and your eligibility to use our products or services, our Website or to enter into a HESA.
• To assist us with providing you access to our Website and your user account as well as a positive and secure experience on our Website.
• To communicate with you for the purposes you indicate when you sign up to receive our products or services or to access and use our Website.
• To provide you with details about new product or service releases, new partnerships and other important information.
• To advertise and promote our products and services to you.
• To learn more about you and your service preferences and to personalize your experience.
• To provide you with customer support services and to process payment of initial fees, if applicable, for products or services offered on our Website.
• To manage and administer our business, and to address problems with, and to improve, our Website including its design, services and offerings.
• To identify and protect against fraud and other criminal activities.
• To carry out our obligations or enforce our legal rights or the rights of those who interact with us, including but not limited to those obligations and rights arising from any contract we may have with you or other parties.
• To comply with legal or regulatory requirements or to protect our safety or the safety of others.
• To detect, prevent and respond to security incidents or other malicious, deceptive, fraudulent or illegal activity.
• To fulfill the purposes for which you provided the personal information or that were described when it was collected.
• To act in accordance with any other purpose with your consent.

If we intend on using any collected personal information for a purpose not previously identified, the new purpose shall be identified to you prior to our use. Unless the new purpose is required by law, consent will be obtained before the information is used for that purpose.

Wherever possible, HEQ Partners limits the amount of personal information it collects, uses or discloses as necessary and appropriate to more efficiently operate our business and serve you.

HEQ Partners may disclose or transfer your personal information to the following entities:

Credit reporting agencies.

• Business partners, such as the financial institutions and insurance companies we work with to offer you our products and services.
• Third-party agents and other service providers that provide us administrative and other services, such as identity verification, marketing or data processing services

To the extent that HEQ Partners enters into arrangements with service providers to store, handle, or otherwise deal with personal information on its behalf, HEQ Partners requires such parties by contractual or other means to provide comparable privacy protection while the information is processed or handled by them. HEQ Partners uses appropriate contractual and other means to ensure that the third party will only use your personal information to perform the services HEQ Partners has specified.

We may also disclose your personal information to a third party if, in our good faith judgement, doing so is required to comply with laws or regulations; respond to a valid subpoena, order, or government request; establish or exercise HEQ Partners’ legal rights, including under our Terms of Use and other agreements or defend against legal claims; investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person; or as otherwise require by law.

If HEQ Partners is to be sold, merged or amalgamated or substantially all of its assets are to be sold or disposed of, your personal information may be transferred to a potential purchaser if, and to the extent necessary, it is required for the purposes of deciding whether to proceed with the proposed transaction and completing it. If such a sale, merger, acquisition, or disposal is completed, the purchaser may use and disclose your personal information only to the extent described in this Privacy Policy.

We may disclose your information in any other way we may describe to you when you provide the information, or for any other purpose with your consent.

Your personal information is stored in secured locations and on servers controlled by HEQ Partners, located either at our offices or at the offices of our service providers.

Our service providers may perform activities outside of Canada. Accordingly, your personal information may be subject to the legal requirements of a foreign jurisdiction including but not limited to the United States, and such jurisdiction may have legal requirements that require us or our service providers to disclose information to courts, law enforcement, or national security authorities.

By submitting your personal information or engaging with our Website, you consent to this transfer, storage, or processing.

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website.

While HEQ Partners takes appropriate measures to protect your personal information, there is always a risk that that it may be lost, intercepted, or misused. HEQ Partners may exchange electronic versions of documents and e-mails with you using commercially available software that may be vulnerable to attack by viruses and other destructive electronic programs. HEQ Partners cannot guarantee that all communications and documents sent via e-mail will always be received, or that such communications and documents will always be virus free. HEQ Partners makes no warranty with respect to the integrity of any electronic communications between us and you or with respect to the security of any such communications and you consent to such exchange of electronic communications with you, including confidential documents.

At any time, you can contact us to stop receiving e-mails from us, review your personal information held by us, withdraw your consent for our use and disclosure of your personal information, or close your account.

While you are generally permitted to withdraw your consent, on reasonable notice, to our use and disclosure of your personal information, legal or contractual restrictions may require us to use or retain your personal information for a certain period of time. We will advise you if this is the case.

You may also amend or request a correction of your personal information in our possession or under our control, subject to certain exceptions which include information that is prohibitively costly to provide, information that contains references to other individuals and/or another individual’s personal information, information that cannot be disclosed for legal, security or commercial proprietary reasons and information that is subject to solicitor-client or litigation privilege.

Please promptly inform HEQ Partners of any changes to your personal information. If you advise us that any personal information in our possession or under our control is inaccurate, incomplete, or not up to date, HEQ Partners will take reasonable steps to correct such information.

If you contact us in respect of any of the items listed above, we may require you to provide sufficient personal information to allow us to identify you and tell you about the existence, use and disclosure of your personal information and this personal information will only be used for this purpose. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any personal information. If you contact us about your personal information, we will respond to your request within a reasonable time and at no cost to you.

Your rights to access your personal information are not absolute. HEQ Partners may deny access when:

• Granting you access would have an unreasonable impact on the privacy of other persons.
• The information is protected by solicitor-client privilege or by litigation privilege.
• Doing so would reveal confidential commercial information.
• The information was generated in the course of a formal dispute resolution process.
• Denial of access is required or authorized by law.

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as is necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous data for any legitimate business purpose without further notice to you or your consent.

Our Website is not intended for children under 13 years of age, and pursuant to our Terms of Use , users of our Website represent and warrant that they are of the legal age of majority. No one under age 13 may provide any information to or on our Website. We do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at sweinreb@theheqpartners.com.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.

You can review and change your personal information by logging into our Website and visiting your account profile page.

By law you have the right to request access to and to correct the personal information that we hold about you. If you want to access, review, correct, or withdraw consent to the use of your personal information you may also send us an email at sweinreb@theheqpartners.com. to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. Exceptions include but are not limited to: information protected by solicitor-client privilege, information that is part of a formal dispute resolution process, information that is about another individual that would reveal their personal information or confidential commercial information, and information that is prohibitively expensive to provide.

Proper access and use of information provided on our Website is governed by our Terms of Use .

Our Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit and contact third-party companies directly if you want to learn more about the privacy practices and security safeguards of such companies.

We welcome your questions, comments, and requests regarding this Privacy Policy and our privacy practices. Please contact us at:

ATTN: Shael Weinreb
sweinreb@theheqpartners.com