Privacy Policy

Last Updated: March 11, 2025

Introduction

Victory Chukwuemeka (hereafter referred to as “we,” “us,” or “our”), a sub-mortgage broker affiliated with BC BEST MORTGAGES GROUP LTD., values your privacy and is committed to protecting it by adhering to the guidelines outlined in this privacy policy. While we are licensed to operate in British Columbia under the British Columbia Financial Services Authority (BCFSA), we welcome inquiries from individuals in other provinces or internationally. Please note that services for non-BC residents may be subject to additional jurisdictional considerations, which we will address on a case-by-case basis. This policy outlines how we handle your personal information in compliance with the Personal Information Protection Act (PIPA) of British Columbia, the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada, and, where applicable, the General Data Protection Regulation (GDPR) for international visitors from the European Union.

1. Who We Are

We are the owners of the website www.victorymortgagebc.ca, and we provide mortgage brokerage services across British Columbia.

2. Information We Collect

We collect personal information to provide mortgage solutions and comply with legal obligations. This includes:

Contact Information: Name, email address, phone number, and mailing address when you request services, book an appointment, or contact us via www.victorymortgagebc.ca or email (contact@victorymortgagebc.ca).
Financial Information: Income, credit history, employment details, and property information, provided during mortgage applications, as required under the British Columbia Financial Services Authority (BCFSA) regulations.
Online Activity: IP address, browser type, and pages visited on our site, collected via cookies or analytics tools (e.g., Google Analytics) to improve user experience.
Communications: Details from emails, phone calls, or forms (e.g., appointment bookings or inquiries).
We do not collect sensitive data (e.g., biometric data) unless required for mortgage processing and with your explicit consent.

3. How We Collect Information

Directly from You: When you fill out forms, book appointments, or discuss mortgage options with us.
Automatically: Via cookies, tracking pixels, or similar technologies when you visit our site. You can manage cookie preferences via your browser settings.
Third Parties: Credit bureaus, employers, or lenders may provide data during mortgage applications, with your consent, as permitted under PIPEDA.
Embedded Content: If our site includes videos or links (e.g., YouTube), third-party sites may collect data. We recommend reviewing their privacy policies.

4. How We Use Your Information

We use your data to:

Providing Services: Assess and process mortgage applications in line with BCFSA and Canadian Mortgage and Housing Corporation (CMHC) guidelines.
Communication: Communicate with you about your mortgage journey, including updates, offers, or appointment scheduling.
Improving Our Website: Improve our website and services based on analytics, ensuring compliance with PIPA BC.
Compliance: Meet legal obligations, such as anti-money laundering laws under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).
Marketing: To send you promotional materials and updates about our services, with your consent. For international visitors (e.g., EU under GDPR), we use data only with consent for marketing purposes, which you can withdraw at any time.

Your Choices

You have choices regarding the information you provide:

Opt-Out: You can opt-out of receiving marketing communications by following the instructions in the communications or contacting us directly.
Access and Correction: You can request access to your personal information and correct any inaccuracies.
Withdrawal of Consent: You can withdraw your consent for the collection, use, and disclosure of your personal information at any time, subject to legal obligations.

5. Consent

By using our services and submitting personal information to us, you consent to our collection, use, and disclosure of such information in accordance with this Privacy Policy and applicable laws. This includes:

Explicit Consent: When you provide personal information through forms, applications, or other interactions, you explicitly consent to our handling of your data as described in this policy.
Implied Consent: Your continued use of our website and services implies consent to our privacy practices.

Parental Consent

For children under the age of 19 in British Columbia or under 16 for international visitors from the European Union, parental or guardian consent is required for the collection, use, and disclosure of their personal information. We obtain this consent through:

Verifiable Process: A signed consent form or email confirmation from a parent/guardian before processing any data.
Clear Communication: Explaining the purpose of data collection and the rights of the parent/guardian.

Withdrawal of Consent

You may withdraw your consent at any time by contacting us. However, withdrawing consent may affect our ability to provide services to you. Upon withdrawal, we will cease further collection and use of your personal information, subject to legal obligations.

6. Cookies and Tracking Technologies

We use cookies on our website (www.victorymortgagebc.ca) to enhance your browsing experience. Cookies are small text files stored on your device that help us recognize you, remember preferences, and analyze site usage. We use CookieYes, a cookie management tool, to provide you with an icon at the bottom of our site where you can adjust your cookie preferences at any time. Our practices comply with the Personal Information Protection Act (PIPA) of British Columbia and the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada.

Types of Cookies

We use the following types of cookies:

Essential Cookies: Necessary for the website to function, enabling features like page navigation and form submissions (e.g., contact form functionality).
Performance Cookies: Collect anonymous data on how visitors use our site, such as which pages are visited most (e.g., via Google Analytics), helping us improve performance.
Functional Cookies: Allow the site to remember your choices (e.g., cookie preferences set via CookieYes) for a more personalized experience.
Targeting Cookies: Used to deliver relevant ads and measure campaign effectiveness (e.g., if we run targeted ads), though currently limited in use.

Managing Cookies

You can manage your cookie preferences in two ways:

CookieYes Tool: Use the cookie icon at the bottom of our website to accept, reject, or customize your cookie settings at any time.
Browser Settings: Most browsers allow you to:
- Block cookies by adjusting settings.
- Delete existing cookies.
- Set preferences for cookie handling. Note that blocking or deleting cookies may impact your experience, such as preventing form submissions or analytics tracking.

Third-Party Cookies

We use third-party services that may set cookies on our behalf:

Google Analytics: Tracks site usage (e.g., page views, session duration) anonymously to improve our services. See their privacy policy at https://policies.google.com/privacy.
YouCanBookMe: Sets cookies for scheduling appointments, such as remembering your session. See their privacy policy at https://youcanbook.me/privacypolicy. These third-party cookies are subject to the providers’ respective privacy policies, and CookieYes allows you to control their use.

Your Consent

By continuing to use our website, you acknowledge our use of cookies as described in this policy. CookieYes provides a pop-up on your first visit to manage your preferences, ensuring transparency. You can withdraw or modify your consent at any time via the CookieYes icon or your browser settings.

For questions or concerns about our use of cookies, please refer to Contact Us section below for our contact details and additional resources.

7. Embedded Content

Our website may include embedded content such as videos (e.g., YouTube tutorials), images, or articles from other websites. This content behaves as if you visited the third-party site directly, allowing those sites to interact with you.

Data Collection

These third-party websites may collect data about you, use cookies, embed additional tracking technologies, and monitor your interactions with the content. This includes tracking if you are logged into their services (e.g., a YouTube account). Examples include viewing statistics or personalized recommendations based on your activity.

Third-Party Privacy Policies

We do not control the privacy practices of these third-party websites. We recommend reviewing their privacy policies for details on data handling. For instance:

YouTube: https://policies.google.com/privacy
Other providers’ policies are linked where applicable.

Your Consent

By interacting with embedded content on our site, you acknowledge that third-party data collection may occur, consistent with implied consent under the Personal Information Protection Act (PIPA) of British Columbia and the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada. You can manage your preferences or limit tracking by adjusting your browser settings or logging out of third-party accounts.

For questions or concerns about embedded content, please refer to Contact Us section below for our contact details and additional resources.

8. Review Policy

We value feedback from our clients to improve our mortgage brokerage services across British Columbia. Reviews provide valuable insights for potential clients and are displayed on our website (www.victorymortgagebc.ca) in accordance with this policy, ensuring transparency and compliance with the Personal Information Protection Act (PIPA) of British Columbia and the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada.

Purpose

Our clients’ reviews help us enhance our services, build trust, and demonstrate our commitment to client satisfaction, aligning with the British Columbia Financial Services Authority (BCFSA) standards for professional conduct.

Submission Guidelines

Eligibility: Only clients who have directly used our mortgage brokerage services are eligible to submit reviews.
Content: Reviews must be honest, reflecting your genuine experience. We encourage constructive feedback, whether positive or negative.
Language: Reviews must use respectful language. We do not accept offensive, defamatory, or inappropriate content (e.g., profanity, discrimination).
Consent: By submitting a review, you consent to its publication on our website, including potential use in marketing materials (e.g., testimonials), with only your first name and last initial displayed.

Moderation

Review Process: We moderate all reviews to ensure compliance with these guidelines. We reserve the right to edit for clarity (e.g., grammar, spelling) or remove reviews that violate this policy.
Verification: We may verify authenticity by contacting you via the email or phone number provided during your service engagement.
Response Time: We aim to review and publish reviews within 7 business days, though this may vary during high-volume periods.
Dispute Resolution: If you disagree with our moderation decision, you can request a review by contacting us. We will respond within 10 business days to ensure fairness.

Display

Featured Reviews: We may highlight select reviews on our homepage or other prominent sections to showcase client experiences.
Transparency: We display all compliant reviews, positive or negative, to provide a balanced perspective, fostering trust with potential clients.
Responses: We may respond to reviews to address feedback or express appreciation, ensuring constructive dialogue.

Privacy

Personal Information: We will only display your first name and last initial (e.g., “John D.”) to protect your privacy.
Data Protection: Personal information collected during the review process (e.g., email, phone) is handled in accordance with our Privacy Policy (see Section 1), ensuring compliance with PIPA BC and PIPEDA.

For questions or concerns about this review policy, please refer to Contact Us section below for our contact details and additional resources.

9. Who We Share Your Data With

We share information only as necessary:

Lenders and Insurers: To process your mortgage, as required by BCFSA and CMHC.
Service Providers: Third parties (e.g., credit bureaus, IT vendors) under strict confidentiality agreements, compliant with PIPEDA.
Legal Authorities: If mandated by Canadian law (e.g., PCMLTFA) or international regulations (e.g., GDPR data requests from EU authorities).
We do not sell your data to third parties for marketing without consent.

10. How Long We Retain Your Data

Mortgage Records: Retained for 7 years after the mortgage term ends, per BCFSA and Income Tax Act requirements.
Inquiries/Comments: Kept for 2 years unless you request deletion, aligning with PIPA BC.
Registered Users: Profile data is retained until you delete your account or request removal.
Data is securely stored on Canadian servers, with backups encrypted for 6 months.

11. Your Rights Over Your Data

Under PIPA BC, PIPEDA, and GDPR (if applicable):

Access: Request a copy of your data by emailing contact@victorymortgagebc.ca.
Correction: Update inaccurate information via the same email.
Deletion: Request data erasure (excluding legal retention obligations) by contacting us.
Objection: Opt out of marketing communications at any time via unsubscribe links or email requests.
We respond to requests within 30 days, as required by law.

12. Data Security

We are committed to protecting your personal information from unauthorized access, use, or disclosure. Our data security practices comply with the Personal Information Protection Act (PIPA) of British Columbia and the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada, ensuring robust safeguards for our mortgage brokerage services provided to BC residents.

Security Measures

We employ the following measures to safeguard your personal information:

Encryption: We use industry-standard protocols like SSL/TLS to encrypt data during transmission (e.g., when you submit inquiries via our website) and AES-256 encryption for data at rest (e.g., stored contact details).
Access Controls: Access to your personal information is limited to authorized personnel at BC BEST MORTGAGES GROUP LTD., with multi-factor authentication required for system access.
Regular Audits: We conduct quarterly security audits to identify vulnerabilities, including penetration testing and compliance checks with PIPA BC standards.
Secure Storage: Data is stored on Canadian servers with physical security (e.g., locked facilities, 24/7 monitoring) and technical safeguards (e.g., firewalls, intrusion detection systems).
Vendor Oversight: Third-party providers (e.g., YouCanBookMe for scheduling) are contractually obligated to maintain similar security standards, and we review their practices annually.

Incident Response

In the event of a data breach, we follow a comprehensive incident response plan to:

Contain and mitigate the breach within 24 hours of detection, using forensic analysis to identify the scope.
Notify affected individuals as soon as feasible, as required by PIPEDA, with details on the breach and protective steps (e.g., monitoring for identity theft).
Report the breach to the Office of the Information and Privacy Commissioner for British Columbia (OIPC BC) or the Office of the Privacy Commissioner of Canada (OPC) within a reasonable timeframe, typically within 72 hours if significant harm is likely, aligning with best practices.
Implement corrective measures to prevent future incidents, such as updating security protocols or staff training.

Your Responsibilities

While we implement robust security measures, you can help protect your data by:

Avoiding sharing personal information with unauthorized parties, especially via unsecured channels.
Keeping your devices and software updated to mitigate vulnerabilities (e.g., installing antivirus software).

For questions or concerns about our data security practices, please refer to Contact Us section below for our contact details and additional resources.

13. International Data Transfers

We may transfer your personal information to third parties outside Canada for processing, such as our scheduling tool provider, YouCanBookMe, which is based in the United States. These transfers comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada and, for international visitors from the European Union, the General Data Protection Regulation (GDPR). Data is transferred only when necessary to provide our mortgage brokerage services across British Columbia and is subject to appropriate safeguards.

Purpose and Scope: Transfers occur to facilitate appointment scheduling, customer support, or legal compliance. We do not transfer data to jurisdictions without adequate protection unless required by law and with your consent where applicable.
Jurisdictional Note: The EU-Canada Adequacy Decision under PIPEDA ensures equivalent protection for EU data, while U.S. transfers (e.g., to YouCanBookMe) rely on additional safeguards due to differing privacy standards.

Safeguards

To protect your personal information during international transfers, we implement the following measures:

Standard Contractual Clauses (SCCs): We use SCCs, approved by the European Commission and recognized by the Office of the Privacy Commissioner of Canada (OPC), to ensure data protection when transferred to third parties like YouCanBookMe.
Technical and Organizational Measures: Data is encrypted during transmission (e.g., SSL/TLS) and stored on secure servers, with access restricted to authorized personnel.
Vendor Compliance: Third-party providers are contractually obligated to adhere to PIPEDA and GDPR standards, and we regularly review their compliance.
Binding Corporate Rules (BCRs): While not currently applicable to our sole proprietorship, we commit to adopting BCRs if our operations expand to include a corporate group, ensuring consistent data protection.

Your Rights

You have the following rights regarding international data transfers:

Request Information: Contact us to obtain details about where your data is transferred and the safeguards applied.
Object to Transfers: You may object to data transfers outside Canada. We will cease such transfers unless legally required, subject to a 30-day review period.
Withdraw Consent: For EU visitors under GDPR, you can withdraw consent for non-essential transfers, and we will adjust processing accordingly.

For questions or concerns about international data transfers, please refer to Contact Us section below for our contact details and additional resources.

14. Children’s Privacy

Our services are not intended for individuals under the age of 19 in British Columbia or under 16 for international visitors from the European Union, as our mortgage brokerage services are designed for adults. We do not knowingly collect, use, or disclose personal information from children under these ages without verifiable parental or guardian consent. If we inadvertently collect such information, we will promptly delete it upon discovery and notify the parent or guardian where feasible.

Age Thresholds: In British Columbia, we adhere to the age of majority (19) under the Infancy Act, reflecting that our services target mature individuals. For EU visitors, we align with the General Data Protection Regulation (GDPR), which considers individuals under 16 as requiring parental consent for data processing.
Non-Collection Intent: Our website (www.victorymortgagebc.ca) and related tools (e.g., contact forms, YouCanBookMe scheduling) are not marketed to children, and we implement age screening where possible (e.g., requiring date of birth for sensitive interactions).

Parental Consent and Rights

Parental or guardian consent is mandatory for any collection, use, or disclosure of personal information from children under 19 in British Columbia or under 16 for EU visitors. We obtain this consent through:

A verifiable process, such as a signed consent form or email confirmation from a parent/guardian, before processing any data.
Clear communication explaining the purpose (e.g., responding to an inquiry) and their rights.

Parents or guardians may:

Review their child’s personal information by contacting us at contact@victorymortgagebc.ca.
Request updates or deletion of their child’s data, excluding information we must retain for legal purposes (e.g., under PIPA BC or PIPEDA).
Withdraw consent at any time, after which we will cease further collection and use, subject to legal obligations.

We respond to such requests within 30 days, as required by Canadian privacy laws.

Safeguards and Education

Data Protection: We employ encryption and access controls to safeguard any inadvertently collected children’s data, complying with PIPA BC and PIPEDA safeguards.
Educational Outreach: We include a notice on our website (e.g., in the footer) stating, “Our services are not for children under 19 (BC) or 16 (EU). Parents, please supervise young users.”
Third-Party Compliance: Our scheduling tool, YouCanBookMe, is instructed not to collect data from minors, and we link to their privacy policy (https://youcanbook.me/privacypolicy) for transparency.

Legal Compliance and Reporting

We comply with the British Columbia Infancy Act (age 19), PIPA BC, PIPEDA, and GDPR (age 16 for EU). If a breach involving children’s data occurs, we will report it to the Office of the Information and Privacy Commissioner for British Columbia (OIPC BC) or the Office of the Privacy Commissioner of Canada (OPC) within 72 hours, as required.
Parents can file complaints with OIPC BC (www.oipc.bc.ca) or OPC (www.priv.gc.ca) if concerns arise.

15. Changes to This Policy

We may update this policy to reflect legal or operational changes. The latest version will be posted at www.victorymortgagebc.ca/privacy-policy with the update date. We’ll notify you via email or site notice for significant changes.

16. Contact Us

For privacy concerns or to exercise your rights, contact:

Name: Victory Chukwuemeka
Email: contact@victorymortgagebc.ca
Phone: 236-978-0106
Address: 130, 709 SE Marine Drive, Vancouver, BC, V5X 2T9
You may also file a complaint with the Office of the Information and Privacy Commissioner for British Columbia (OIPC BC) at www.oipc.bc.ca or the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca.