Privacy statement
Licit Action Defence Solutions Inc. (“Licit ADS”, “we”, “us”) respects your privacy. This statement explains what personal information we collect, why we collect it, who we share it with, and the choices you have. It is written to meet the requirements of the federal Personal Information Protection and Electronic Documents Act (PIPEDA), which governs private sector organisations carrying on commercial activity in Ontario.
Who this applies to
This statement applies to our website, our client portal, and any information you give us by email, telephone or in person when you ask us to review or support a file.
It applies to clients, to prospective clients who register but do not proceed, and to the mortgage brokers, sales representatives and third party service providers who use the portal.
What we collect
Contact and account information: your name, email address, telephone number, mailing address, and the credentials you use to sign in.
Identity verification information: the type and number of a government issued identification document, your date of birth, the last three digits of your Social Insurance Number, and your property or mailing address. We collect the last three digits of a SIN only to distinguish between individuals with similar identifying details. We do not require, and ask you not to send, your full SIN.
File information: the debt type, the approximate amount owing, the date you were served or received a notice, a description of what you received, and the documents you upload, which may include court documents, mortgage and loan agreements, statements of account, credit reports and proof of address.
Account and payment information: charges, credits, discounts, payments recorded against your account, invoices, and the method of each payment. Card details are handled by our payment processor. We do not store full card numbers on our systems.
Referral information: the broker, sales representative or referral code associated with your file.
Messages exchanged in the portal, and a record of actions taken on your file, including who took them and when.
Technical information from your device when you use the site or portal, such as your IP address, browser type and pages visited.
Why we collect it
To confirm your deadline and review your file.
To verify your identity, meet our record keeping obligations, and guard against fraud and misuse of the service.
To coordinate a response through the appropriate counsel channel and, where a file is accepted, with the third party service provider assigned to it.
To administer your account: to issue your total for service, to record charges, discounts, waivers and payments, to issue invoices and statements, and to assess a request for financing or a one time payment option.
To communicate with you, and to keep the parties on your file informed to the extent each is entitled to know.
To operate, secure and improve the site and the portal, and to comply with the law.
Consent
We collect, use and disclose your personal information with your consent, except where the law permits or requires us to act without it. You give consent when you register, when you confirm your identity details, and when you upload a document or send a message.
You may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Withdrawing consent may mean we can no longer review or support your file. Tell us in writing at the contact address below.
Where a document you send contains personal information about another person, such as a joint borrower or a spouse, you confirm that you have their authority to provide it.
What a broker or sales representative can see
A referral partner sees only the clients who selected them at registration, and only the progress of those files: the service, the approximate amount, the file status, whether a provider has been assigned, how many documents have been accepted, and their own message channel with you.
A referral partner never sees your identity verification details, the contents of your uploaded documents, your account balance, your invoices or your payment information.
If you ask a referral partner for help, you may give them permission from your portal to upload documents you have not provided and to fill identity fields you have left empty. They cannot see details already on file. Everything they add is recorded against their name, reported to Licit ADS, and shown to you. You may withdraw that permission at any time.
Where information is held
Your information is stored on servers in Canada or the United States, depending on the supplier. Where information is held or processed outside Canada it may be accessible to the courts, law enforcement and national security authorities of that country.
We require our suppliers to provide a comparable level of protection to the one described in this statement.
How we protect it
We use administrative, technical and physical safeguards appropriate to the sensitivity of the information, including encryption in transit, access controls that limit each role to what it needs, and logging of actions taken on a file.
No system is completely secure. If a breach creates a real risk of significant harm, we will notify you and the Office of the Privacy Commissioner of Canada as PIPEDA requires.
How long we keep it
We keep your file for as long as needed for the purposes described here and to meet our legal, accounting and record keeping obligations, and then we destroy, erase or anonymise it.
If you register but do not proceed, we keep the registration for a limited period so we can respond if you come back, and then remove it.
Your rights
You may ask what personal information we hold about you, how we have used it and to whom we have disclosed it. We will respond within thirty days, or tell you if we need longer.
You may ask us to correct information that is inaccurate or incomplete.
You may withdraw consent, subject to the limits described above.
In limited cases the law allows us to withhold information, for example where releasing it would reveal personal information about someone else or is subject to solicitor client privilege. Where we withhold, we will tell you why.
Questions and complaints
Our Privacy Officer is responsible for our compliance with this statement. Write to info@licitads.com, for the attention of the Privacy Officer.
We will acknowledge your enquiry and investigate it. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at priv.gc.ca or 1-800-282-1376.
Changes to this statement
We may update this statement as the service or the law changes. Canada's federal private sector privacy law is currently under review, and this statement will be revised if the law is replaced.
The date at the top shows when it was last updated. Material changes will be brought to your attention in the portal.