First Horizon Financials Inc. Privacy Policy

Protecting your personal information is crucial, especially when dealing with financial matters. First Horizon Financials Inc.(FHF) prioritizes privacy and confidentiality. Your privacy is protected at all times. We are committed to provide you with service excellence is our respect for your right to privacy.

We collect, use and disclose information to:

• Identify you and verify any information you give us
• Protect all parties from error and fraud
• Understand your needs and eligibility for products and services
• Recommend products and services so we may serve you better
• Meet legal requirements, such as asking you to provide the necessary information to verify your identity
• Present your mortgage application to various lenders for the purpose of securing a mortgage and/or related service

Your information and the business you do with us is kept strictly confidential

Your information will be protected from error, loss and unauthorized access. Our procedures and systems are designed to ensure this security. We collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances. As well, we never sell any information about our customers to others, and we only keep information as long as it is needed.

Your information is obtained or used only with your consent we obtain your (express or implied) consent before we:

• Check your employment
• Obtain a credit report
• Offer you other products and services
• Obtain, use or disclose to other persons, information about you unless we are obliged to do so by law or to protect our interests
• Use your information in any way we didn’t tell you about previously
• You can withdraw your consent any time after you’ve given it to us, provided there are no legal requirements to prevent this, by contacting your Mortgage Centre Specialist.

We may tell you about products and services through direct mail, telephone, or other means. If you do not wish us to do so, advise your HB Mortgage Centre Specialist.

We don’t share information about you, except as is necessary to complete your mortgage application and take all steps necessary to secure mortgage financing on your behalf, nor do we release it to anyone else, without your express or implied consent. However, there are some exceptions. For example, we may collect, use or disclose information without your consent if we:

• are obligated or permitted to do so for legal reasons
• use an outside company, to do work for us involving some of your information

You can review your personal information held by us and make corrections to it by contacting your Mortgage Centre Specialist. You may be asked to put your request in writing.

Keeping our customers’ information and affairs in strict confidence is a cornerstone of FHF’s business. The range of products and services we offer our customers continues to expand, and the technology we use continues to change. But, no matter how our business changes, we’ll always protect your privacy.

In the following sections we describe these policies and procedures and how we put them into practice so that you have control over how we collect, use and disclose your information.

Protecting your privacy means:

• we keep your information and the business you do with us in strict confidence
• your information is not sold
• you have control over how we obtain, use, and give out information about you
• you have access to the information we have about you
• we respect your privacy when we market our products and service
• Our privacy policies protect all of our customers

Certain information, such as a driver’s license, although convenient for identification, is voluntary. It is up to you whether you want to provide those or some other suitable identification, subject to any legal requirements.

We collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances.

Your information is obtained or used only with your consent.

When we obtain a report and update your information with a credit bureau, your SIN is the best way to make sure that the information actually refers to you. Wrong information could lead us to draw wrong conclusions about you. You should be aware, though, that providing us your SIN for use this way is voluntary for you. If you choose not to give us your SIN when its collection is optional, this by itself will not prevent you from getting any products or services.

Your consent can be express or implied

• Express consent can be verbal or written. For example, when you sign a credit application you are giving your written consent for us to obtain a credit report.
• You imply consent when we can reasonably conclude that you’ve given consent by some action you’ve taken, or when you decide not to take action. If we give you an opportunity to tell us you don’t want direct marketing material and you don’t tell us that you don’t want us to send it, we can conclude that you have no objection. We will rely on your implied consent to use and disclose identifying information about you, such as your name and address.

You can withdraw your consent after you’ve given it

• You can withdraw your consent any time after you’ve given it to us, provided there are no legal requirements to prevent this. However, in order to maintain the integrity of the credit reporting system, we do have to update your credit information with the credit bureau as long as you have credit with us. Your consent for this purpose cannot be withdrawn during this time.
• If you don’t consent to certain uses of information, or if you withdraw your consent, we may not be able to provide you with a particular product or service. If so, we’ll explain the situation to you to help you with your decision.

We ask for your consent before sharing information with other people

• We don’t share information about you, or release it to anyone outside of HB Mortgage Centre without your consent. For example, we give information to a credit bureau only with your consent.

We protect your information from error, loss and unauthorized access

Our employees who have access to your information are made aware of how to keep it confidential. Each employee must sign an agreement stating that maintaining confidentiality is a condition of employment with FHF

Our computer security specialists build security into all our computer systems.

• This protects your information at all times, when it is stored in data files or handled by our employees. Our systems also protect your information when it is transmitted.

Your information is destroyed when it is no longer needed

• We keep your information only so long as we need it for the products and services you’re using, to offer you products and services when you are a customer and for a reasonable time thereafter, or to meet any legal requirements. We have retention standards which meet these requirements. We destroy your information when it is no longer needed, or we remove your name from the information.

You can see and verify the accuracy of your information

• You can check your information to verify, update and correct it, and to have any obsolete information removed. We may ask you to put your request in writing.
• There’s no charge for verifying or correcting your information. Depending on the circumstances, there may be a charge if you want a copy of records which we have already given you. We will let you know in advance if there is a charge.
• If you have a sensory disability, we will give you access to your personal information in any alternative format you request if we already have it in that format or if its conversion into that format is reasonable and necessary in order for you to be able to exercise your rights under applicable legislation.

You can find out to whom we’ve given information about you

• If you ask, we will let you know the names of outside companies or organizations we’ve given information to. This won’t include information given to outside companies we’ve used to do work for us, such as cheque printers. It won’t include T5 reports to the Canada Customs and Revenue Agency, or regular updates of credit information to credit bureau.

We respond to your request promptly

• We’ll deal quickly with your request to see your information, and always respond to you within 30 days. If we need to extend the time, or we have to refuse your request, we’ll tell you why, subject to any legal restrictions and we’ll notify you of the new deadline, the reasons for the extension, and your rights under applicable legislation respecting the extension.

We correct your information

• Whenever possible, we’ll correct any information which we may have given to an outside organization.
• If a third party, such as a credit bureau, has given us information which you tell us is wrong, we’ll give you the name and address of that party so that you can correct the information.

If you have any questions or complaints about our privacy policies, you can contact us.