Privacy Policy

  1. Introduction

This Privacy Policy (“Privacy Policy” or “Policy”)) describes the information collection, use, protection and disclosure practices of Glasslake Funder ULC (the “Company”, “Glasslake”, “we”, “us”, or “our”) of nonpublic personal identifying information about consumers when you use “Glasslake” brands, including without limitation, the Glasslake Website (the “Website”) and the Products or Services provided by us through the Website as described in the respective Terms of Use.

Glasslake is a private mortgage lender and licensed mortgage brokerage based in Ontario, and licenced in Ontario, Alberta, and British Columbia.  We are committed to protecting personal information in accordance with applicable Canadian laws, including the Personal Information Protection and Electronic Documents Act, and regulatory expectations of the Financial Services Regulatory Authority of Ontario and of other provincial regulators where Glasslake conducts business.

Glasslake recognizes the importance of keeping the information that identifies, relates to, describes, references, and is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”) private and secure. Glasslake has developed a comprehensive privacy policy, and we use the latest technology to ensure that your Personal Information is secure.

The purpose of this Privacy Policy and disclosure is to inform you, at or before the time of collection of Personal Information and to inform you as part of our privacy policies. This Privacy Policy also explains any rights you may have about these privacy practices.

 

  1. Accountability and Governance

Glasslake has designated a Privacy Officer responsible for compliance with this policy and applicable privacy laws.

We maintain policies and procedures designed to ensure:

  • Proper handling of client information
  • Staff training and confidentiality obligations
  • Oversight of third-party service providers
  • Compliance with mortgage brokerage regulatory requirements

 

Contact information for our Privacy Officer and Glasslake is available at the end of this Policy.

 

  1. What Information We Collect

Information You Provide

Glasslake may collect certain types of information from you, such as information you voluntarily provide via forms, surveys, applications, etc. when you visit the Company’s Website. The specific information we collect depends on the context to which you provide it and/or interact with our Website and/or Products and/or Services, and could include:

  • Name
  • Email Address
  • Postal Address
  • Phone Number
  • Social Insurance Number
  • Location and approximate value of your property
  • Age and/or date of birth
  • Financial information, such as income, assets and net worth
  • Home ownership status and employment status
  • Insurance information
  • Other profile data, including interest and preferences
  • Any other information you provide

 

Information We Automatically Collect

We may also automatically collect information about you from your interactions with us via our Website, and/or Products and/or Services through online browsing and transactions, including but not limited to:

  • Transactional Information.
  • Device and Usage Information
  • Location Information.
  • Information Collected by Cookies and Similar Tracking Technologies:

o Cookies

o Web beacons

o Software development kits.

 

Glasslake may collect information from third-party sources in certain circumstances.

Information received from these third parties varies depending on the type of information made available by these entities. Examples include:

  • Financial account information
  • Information about account balance(s)
  • Information about credit accounts
  • Information about loan accounts
  • Information about investment accounts
  • Identifiers and information from account owners
  • Information about account transactions
  • Employment information.

 

We may incorporate products and services that use artificial intelligence, including large language models and machine learning, to derive this information and draw these inferences.

We collect information necessary to assess suitability, arrange, and administer mortgage products, including:

  • Identification (name, date of birth, government ID)
  • Contact details
  • Financial and credit information
  • Employment and income verification
  • Property and loan details
  • Transaction history
  • Know-Your-Client (KYC) and anti-money laundering information
  • Website and technical data (e.g., IP address, browsing activity)

 

  1. How We Collect Information

We collect personal information:

  • Directly from you
  • Through mortgage brokers, agents, and referral partners
  • From third parties with consent, including:
    • Credit bureaus
    • Financial institutions
    • Employers
    • Appraisers and other real estate professionals

 

This aligns with our obligations to assess suitability and verify information under mortgage brokerage regulations.

 

  1. Purposes for Collection, Use, and Disclosure

We use personal information to:

  • Assess your needs and suitability for mortgage products
  • Process, underwrite, fund, and service loans
  • Verify identity and detect, identify, investigate, and prevent fraud
  • Meet legal and regulatory obligations (including AML requirements)
  • Communicate with you regarding your mortgage or application
  • Maintain records required by regulators
  • Improve our services and operations

 

  1. Consent

We obtain your consent to collect, use, and disclose your personal information, except where permitted or required by law.

Consent may be:

  • Express (e.g., signed application forms)
  • Implied (e.g., when you provide information for a mortgage application)

You may withdraw consent at any time, subject to legal and contractual limitations. Doing so may affect our ability to provide services.

 

  1. Disclosure of Personal Information

We do not sell personal information.

We may share your information with:

  • Lenders, investors, and funding partners
  • Mortgage brokers and agents involved in your transaction
  • Credit reporting agencies
  • Service providers (IT, payment processing, document storage)
  • Regulators, including Financial Services Regulatory Authority of Ontario, British Columbia Financial Services Authority, and Real Estate Council of Alberta, where required
  • Law enforcement or government authorities where required by law
  • Affiliates, where permitted

We require third parties to protect personal information and use it only for authorized purposes.

Some service providers may operate outside Canada, and your information may be subject to foreign laws.

 

  1. Marketing Communications (CASL Compliance)

Glasslake complies with Canada’s Anti-Spam Legislation when sending electronic communications.

We may send you commercial electronic messages (e.g., email, SMS) about our products and services only where:

  • You have provided express consent; or
  • We have an existing business relationship, as defined by law

All marketing communications will:

  • Clearly identify Glasslake as the sender
  • Include our contact information
  • Provide a simple, no-cost unsubscribe mechanism

You can withdraw your consent to receive marketing communications at any time by:

  • Clicking the unsubscribe link in emails
  • Contacting us directly

We will process unsubscribe requests promptly in accordance with applicable law.

 

  1. Safeguards

Glasslake will take reasonable steps to protect Personal Information with reasonable security safeguards appropriate to the sensitivity of the information. We will use reasonable safeguards to protect personal information from theft, modification, unauthorized access, collection, use, disclosure, loss and destruction. However, we will not be responsible in relation to the events listed above if done by a third party.

 

  1. Retention of Personal Information

We retain personal information only as long as necessary to:

  • Fulfill the purposes identified
  • Satisfy legal, regulatory, and audit requirements (including brokerage record-keeping obligations)

We will keep Personal Information as long as necessary for the purposes identified in this Privacy Policy, which will be at least as long as any balance remains outstanding on any loan provided, and thereafter during any period after settlement of all balances during which any readjustment or claim is not statute barred.

Information is securely destroyed or anonymized when no longer required.

 

  1. Accuracy & Requests for Correction

We take reasonable steps to ensure that personal information is accurate, complete, and up to date as required for the purposes for which it is used.

The law permits individuals to submit written requests to us to correct errors or omissions in their Personal Information that is in our custody or control.  We will:

  • correct the Personal Information and, if reasonable to do so, send correction notifications to any other organizations to whom we disclose the incorrect information; or
  • decide not to correct the Personal Information, but annotate the Personal Information that a correction was requested but not made.

 

  1. Access and Correction

Upon a request in writing, within a reasonable time Glasslake will inform you of the existence, use, and disclosure of your Personal Information, and you will be given access to that information, except where the law requires or permits us to deny access.  For example, we will not disclose Personal Information to you if the disclosure would reveal Personal Information about another individual.  There may be a reasonable cost attached to the request depending on the type and amount of information requested, such as copying or postage fees.

Furthermore, except where the law requires, we will not provide you with Personal Information if it:

  • is not readily retrievable and the cost of retrieval cannot be justified;
  • includes Personal Information about other customers or persons;
  • contains our own proprietary information, such as a credit scoring formula, assessment of risk, or collection recommendations;
  • cannot be disclosed for legal reasons;
  • is subject to solicitor client or other privilege; or
  • is used for the detection or prevention of criminal activity, including fraud, and dealings in proceeds of crime.

 

  1. Website, Cookies, and Analytics

Our website uses cookies and similar technologies to:

  • Improve functionality and user experience
  • Analyze usage and performance
  • Support security and fraud prevention

You may disable cookies through your browser settings, though this may affect site functionality.

 

  1. Third-Party Websites

Our website may contain links to third-party websites. We are not responsible for their privacy practices.

 

  1. Changes to This Policy

We may update this Privacy Policy periodically. The updated version will be posted on our Website (glasslake.ca) with a revised effective date.

 

  1. Contact Us

In the event that you need to contact us about this Privacy Policy or our privacy practices, please contact us at:

Glasslake Funding ULC.
1501 – 225 King Street West, Toronto, Ontario.  M5V 3M2

Ontario Broker Licence No. 13527
Alberta Broker Licence No. 2124490851
British Columbia Broker Licence No. MB604939

 

Privacy Officer

Douglas Robinson

douglasrobinson@glasslake.ca

_________________________________________________________________

If you are not satisfied with our response, you may contact:

  • Office of the Privacy Commissioner of Canada
  • Information and Privacy Commissioner of Ontario
  • Office of the Information and Privacy Commissioner for British Columbia
  • Office of the Information and Privacy Commissioner of Alberta

 

Glasslake Funding ULC is a member of the Bayview family of companies and a subsidiary of Bayview Asset Management, LLC (“Bayview”).