This policy explains how Michael Giligson, operating Unlocking the Mortgage Code at https://www.unlockingthemortgagecode.ca ("we", "us", "our"), collects, uses, discloses and protects personal information. We follow Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), British Columbia's Personal Information Protection Act (PIPA) where it applies, Quebec's Act respecting the protection of personal information in the private sector for visitors in Quebec, and Canada's Anti-Spam Legislation (CASL).
The short version
- The calculators run entirely in your browser. The numbers you type into them are never sent to us.
- We only collect your name and email address if you give them to us, for example to receive the worksheet pack.
- We only send you marketing emails if you tick the box to say yes. Every email has a working unsubscribe link.
- We don't sell your personal information.
- Google may use cookies on this site to show ads. You can turn off personalized ads at any time.
1. Who is responsible
Michael Giligson is responsible for personal information under our control and acts as our privacy officer (for Quebec purposes, the person in charge of the protection of personal information). You can reach the privacy officer at:
Michael Giligson, Privacy Officer
Unlocking the Mortgage Code
Rethink Financial, 1100-1200 W 73rd Ave, Vancouver, BC V6P 6G5
rethinkfinancial@gmail.com
2. What we collect
Information you give us
- Worksheet requests and email sign-ups: your first name (optional), email address, and whether you agreed to receive updates.
- Consent records: when you give consent to receive emails, we record the date and time, the form and wording you agreed to, and the technical details our email provider (MailerLite) logs with the sign-up. We keep these to prove consent, as CASL requires.
- Messages you send us: your name, email address and whatever you choose to include.
Information you don't give us
The calculators process everything in your web browser. Home prices, balances, rates and other figures you enter are not transmitted to us or stored by us.
Information collected automatically
- Server logs. Like most websites, our web host automatically records technical information when you visit, such as your IP address, browser type, the pages you request and the time of the request. This is used to keep the site running and secure.
- Site statistics. We may use an analytics service, such as Google Analytics, to understand which pages are used and how visitors find the site. Analytics services use cookies or similar technology and report aggregated statistics to us.
- Advertising cookies. See section 6.
- Web fonts. Our pages load fonts from Google Fonts. When your browser requests a font, Google receives your IP address and browser details.
3. Why we use it
- To send you the worksheet pack or other material you request.
- If you've given express consent, to send occasional emails about Canadian mortgage rules, renewals, new guides and calculators, and the book.
- To answer your questions and correction requests.
- To operate, secure and improve the site.
- To show advertising that helps keep the site free.
- To keep records required by law, such as proof of email consent.
We don't use your information for any other purpose without telling you and, where required, asking for your consent.
4. Email and Canada's Anti-Spam Legislation (CASL)
We ask before we send
We send commercial emails, such as updates, new guides and news about the book, only to people who have given express consent by ticking an unchecked box on our sign-up form. That box is always optional. If you request the worksheet pack and leave the box unchecked, we send only the pack you asked for.
When we ask for consent, we tell you why we're asking, who is asking (Michael Giligson, Unlocking the Mortgage Code), our mailing address and contact information, and that you can withdraw consent at any time.
Every email identifies us
Every commercial email we send includes our name, our mailing address, a way to contact us, and an unsubscribe link.
Unsubscribing
- Click the unsubscribe link at the bottom of any email, or email us at rethinkfinancial@gmail.com with "unsubscribe" in the subject line.
- Unsubscribing is free and takes one step.
- We act on unsubscribe requests without delay, and in any case within 10 business days, as CASL requires.
- The unsubscribe link in each email remains valid for at least 60 days after the email is sent.
After you unsubscribe, we keep your email address on a suppression list so we don't accidentally email you again. We also keep the record of your original consent and withdrawal for up to three years, to demonstrate that we complied with the law.
5. Cookies
Cookies are small files stored by your browser. This site's calculators don't need cookies. Cookies may be set by our analytics provider and by advertising partners, as described in section 6. You can block or delete cookies in your browser settings. The site will still work, but you may see less relevant ads.
6. Advertising
We use Google AdSense to display advertising on this site.
- Third-party vendors, including Google, use cookies to serve ads based on your prior visits to this website and other websites.
- Google's use of advertising cookies enables it and its partners to serve ads to you based on your visits to this site and/or other sites on the internet.
- You can opt out of personalized advertising by visiting Google Ads Settings.
- You can opt out of some third-party vendors' use of cookies for personalized advertising at www.aboutads.info/choices, and, in Canada, through the Digital Advertising Alliance of Canada's YourAdChoices program.
- Other ad networks and vendors may serve ads through Google's network. Each is listed on Google's ad technology provider list and offers its own opt-out where available.
To learn how Google uses information from sites that use its services, see How Google uses information from sites or apps that use our services.
Where the law requires your consent before personalized advertising cookies are used, including for visitors in Quebec, the European Economic Area, the United Kingdom and Switzerland, we ask for that consent through a cookie message, and you can change your choice at any time. If you decline, you may still see non-personalized ads.
7. Who we share information with
We don't sell, rent or trade personal information. We share it only with service providers who help us run the site and send email, and only as needed for those tasks:
- our website hosting provider,
- MailerLite, our email delivery provider, which stores our mailing list and sends our emails,
- Google, for advertising, analytics and web fonts, as described above.
We require our service providers to protect personal information and use it only to provide their services to us. We may also disclose information if required by law, such as in response to a court order.
8. Storage outside Canada
Some of our service providers store or process information outside Canada, including in the European Union and the United States. While it's there, it's subject to the laws of those places, and may be accessible to their courts, law enforcement and national security authorities.
9. How long we keep it
- Mailing list: until you unsubscribe or ask us to delete it, plus the suppression record described in section 4.
- Worksheet-only requests: up to 12 months, unless you also consented to updates.
- Messages you send us: up to two years after we last correspond, unless we need them longer to resolve an issue.
- Server logs and analytics: according to our providers' standard retention periods.
When we no longer need information, we delete or anonymize it.
10. How we protect it
We use reasonable safeguards for the sensitivity of the information we hold, including encrypted connections (HTTPS), reputable service providers, strong passwords and two-factor authentication on our accounts, and limiting access to the information. No system is perfectly secure. If a breach of security safeguards creates a real risk of significant harm to you, we'll notify you and the appropriate privacy commissioner as the law requires.
11. Your rights
You have the right to:
- ask what personal information we hold about you and how it has been used and disclosed,
- ask us to correct information that is inaccurate or incomplete,
- withdraw your consent at any time, including by unsubscribing, subject to legal requirements,
- ask us to delete your information, subject to the records we must keep by law,
- if you're in Quebec, the additional rights available to you under Quebec law.
To make a request, contact our privacy officer using the details in section 1. We'll respond within 30 days, and may need to confirm your identity first. There's no charge.
12. Complaints
If you have a concern, please contact us first so we can try to fix it. If you're not satisfied, you can contact:
- the Office of the Privacy Commissioner of Canada,
- the Office of the Information and Privacy Commissioner for British Columbia, or
- in Quebec, the Commission d'accès à l'information.
Complaints about spam or unsubscribe problems can also be reported to the federal Spam Reporting Centre.
13. Children
This site is intended for adults making mortgage decisions. We don't knowingly collect personal information from anyone under 18. If you believe a minor has given us information, contact us and we'll delete it.
14. Changes to this policy
We may update this policy as our practices or the law change. We'll post the new version here with a new effective date. If we make a significant change to how we use information you've already given us, we'll ask for your consent where required.