FRANK MORTGAGE PRIVACY POLICY

Frank Fintech Inc. (dba Frank Mortgage) and its affiliates (collectively, “Frank Mortgage”, “we”, “our” or “us”)

recognize the importance of privacy. The purpose of this privacy policy (“Privacy Policy”) is to inform you (“you” or

“your”) about our privacy practices, including how we collect, use and disclose your Personal Information (as

defined herein).

This Privacy Policy applies to all of our operations in Canada or operations in connection with Canada, unless we

have provided you with a separate privacy policy for a particular product, service or activity.

Privacy Policy Updates

This Privacy Policy is current as of the “last updated” date which appears at the top of this page. We may modify

this Privacy Policy from time to time and we will provide you of notice of changes to this Privacy Policy. When

changes are made to this Privacy Policy they will become effective on the date set out in any notice or on the

“updated” date as published in a revised Privacy Policy posted on our website.

Please review this Privacy Policy carefully. By submitting your Personal Information to us, by registering for or

using any of the services we offer, by using our website, or by voluntarily interacting with us, you consent to our

collecting, using and disclosing your Personal Information as set out in this Privacy Policy, as revised from time to

time.

Frank Mortgage services may allow you to access services provided by others and to interact with other service

providers. Where you choose to use services provided by others or interact with other service providers, you

consent to us disclosing your Personal Information to those third party service providers to facilitate your use or

interaction with those services and providers.

WHAT THIS PRIVACY POLICY COVERS

This Privacy Policy covers the following topics:

• Meaning of Personal Information
• Your Consent to Collection, Use and Disclosure
• Personal Information We Collect
• How We Use Your Personal Information
• How We Share Your Personal Information
• Opting Out of Communications
• Retention of Personal Information
• Information Security
• Accessing and Updating Your Personal Information
• International Transfer and Storage of Information
• Third Party Services
•  How to Contact Us

Meaning of Personal Information

"Personal Information"; means information about an identifiable individual as described under Canadian privacy

laws. This information may include (without limitation) your name, mailing address, e-mail address, telephone

number, other contact information you provide to us, professional or employment information, banking

information, and payment information.

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Personal Information does not include any business contact information that is solely used to communicate with

you in relation to your employment, business or profession, such as your name, position name or title, work

address, work telephone number, work fax number or work e-mail address.

Personal Information also does not include information that has been de-identified, anonymized, or aggregated in

such a way that there is no serious possibility it can be used, or where it could not be used in reasonably

foreseeable circumstances, to identify an individual whether on its own or in combination with other information.

Your Consent to Collection, Use and Disclosure

We collect, use and disclose your Personal Information with your consent or as permitted or required by Canadian

privacy laws. How we obtain your consent (i.e., the form we use) will depend on the circumstances, as well as the

sensitivity of the information collected. Subject to applicable laws, your consent may be express or implied,

depending on the circumstances and the sensitivity of the Personal Information in question.

If you wish to withdraw your consent to our collection, use or disclosure of your Personal Information, please

contact us using the contact information in the “How to Contact Us” section below. However, before we

implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your

consent may mean that we will no longer be able to provide you with certain products or services.

If you provide Personal Information about another individual to us, it is your responsibility to obtain the consent of

that individual to enable us to collect, use and disclose his or her information as described in this Privacy Policy.

Personal Information We Collect

The Personal Information we collect is generally in one or more of the following categories.

• Products and Services. For individuals located in Canada who use our products and services, we may
• collect information from you or from your use of our products or services.
• We collect Personal Information that you submit through your use of our products or services,
• such as (without limitation) your name, e-mail address, telephone number, other contact
• information, professional or employment information, banking information, and payment
• information.
• We may also automatically collect usage data that is identifiable with you when you use our
• products and services.

Website. For individuals located in Canada who visit our website located at https://frankmortgage.com or

any of our related websites, including to access the Frank Mortgage platform (collectively, “our website”),

we may collect information from you or from your activities on our website.

• Like most websites and other Internet services, we may collect certain technical and device

information about your use of our website. Such information may include your Internet protocol

address, information about your device, browser and operating system, and the date and time of

your visit.

• We may use “cookies” or enlist third party services which use cookies to track your preferences

and activities on our website. Cookies are small data files transferred to your computer’s hard-

drive by a website. They keep a record of your preferences, making your subsequent visits to that

website more efficient. Cookies may store a variety of information, including the number of

times that you access a website, your language preferences and the number of times that you

view a particular page or other item on that website. The use of cookies is a common practice

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adopted by most major websites to better serve their users. Most browsers are designed to

accept cookies, but they can be modified to block cookies. Without cookies some of our

website’s functions may not be available.

• We may also use “web beacons” to better understand how our website is being used and to

enhance your online experience. Web beacons are Internet tools that help us determine, for

example, whether a page of our website has been viewed.

• You have a variety of tools to control the data collected by cookies, web beacons, and similar

technologies. For example, you can use controls in your internet browser to limit how the websites you

visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.

Other Interactions. For individuals located in Canada who otherwise interact with us, whether in person,

by phone or email, through social media or otherwise, including individuals who might be interested in

acquiring our products or services, who sign-up to receive newsletters or other communications, who

respond to surveys and questionnaires, or who submit testimonials or other feedback, we may collect

information that you provide to us during these interactions. This information may include your name, e-

mail address and other contact information.

How We Use Your Personal Information

We may use your Personal Information for purposes such as:

• providing you with our products and services and supporting your use of our products and services;
• to improve the effectiveness and safety of Frank Mortgage services;
• monitoring the usage of our products and services to support their proper functioning and further

improvement;

• analyzing the needs and activities of our customers to help us better serve them;
• generating de-identified data to conduct research and analysis related to our business, products and
• services;
• responding to inquiries and other requests;
• collecting opinions and comments about our products and services;
• providing you with information that we think may interest you, including information about our products

and services; and

• investigating legal claims.

We may use your Personal Information for purposes for which we have obtained your consent, and for such other

purposes as may be permitted or required by applicable Canadian privacy laws.

We may use the information that we collect to advertise third party products and services or targeted advertising

of Frank Mortgage products and services across third party websites or service offerings. You may opt-out by

contacting us directly using the contact information in the “How to Contact Us” section below.

How We Share Your Personal Information

Frank Mortgage services may allow you to access services provided by others and to interact with other service

providers. Where you choose to use services provided by others or interact with other service providers, we will

disclose your Personal Information to those third party services providers to facilitate your use and interactions

with those services and providers.

We rely on third party services providers (including affiliates) to perform a variety of services on our behalf, such as

(without limitation) hosting, data storage and processing service providers, telecommunications carriers, email

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providers, telephone and technical support providers, research and analytics providers, and providers of credit

reporting and identity verification services.

If we provide your information to service providers, then we require that the service providers keep your Personal

Information secure, and only handle it for limited purposes for which it is provided. We do not authorize the

service providers to disclose your Personal Information to unauthorized parties or to use your Personal

Information for their own purposes. If you would like more information about our service providers, please contact

us using the contact information in the “How to Contact Us” section below.

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted,

necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply

with legal process; (c) to respond to requests from public and government authorities, including public and

government authorities outside your country of residence; (d) to enforce the terms of the agreements for our

products and services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies

or limit the damages that we may sustain. In addition, we may transfer your Personal Information and other

information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or

other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets, or other

business transaction.

If we otherwise intend to disclose your Personal Information to a third party, we will identify that third party and

the purpose for the disclosure, and obtain your consent.

Opting Out of Communications

If you no longer want to receive marketing-related emails from us, you may opt-out of receiving marketing-related

emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt-out by

contacting us directly using the contact information in the “How to Contact Us” section below.

We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable

time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still

need to send you communications about your use of our products or services, or other matters.

Retention of Personal Information

We will use, disclose or retain your Personal Information only for as long as necessary to fulfill the purposes for

which that Personal Information was collected and as permitted or required by Canadian privacy laws.

Information Security

We have implemented physical, organizational, contractual and technological security measures with a view to

protecting your Personal Information from loss or theft, and unauthorized access, disclosure, copying, use or

modification. We have taken steps to ensure that the only personnel who are granted access to your Personal

Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

Despite the measures outlined above, no method of information transmission or information storage is 100%

secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that

your interaction with us is no longer secure (for example, if you feel that the security of any information that you

provided to us has been compromised), please contact us immediately using the contact information in the “How

to Contact Us” section below.

Accessing and Updating Your Personal Information

You may make a written request to review any Personal Information about you that we have collected, used or

disclosed, and we will provide you with any such Personal Information to the extent required by applicable laws.

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You may also challenge the accuracy or completeness of your Personal Information in our records. If you

successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend

the Personal Information as required.

We may require that you provide sufficient identification to fulfill your request to access or correct your Personal

Information. Any such identifying information will be used only for this purpose.

International Transfer and Storage of Information

Your Personal Information may be stored and processed at our offices in Canada or at the offices of our third party

service providers, or at data centers managed by us or third party service providers, in Canada and the United

States. Other jurisdictions may have different data protection rules than Canada. While your Personal Information

is outside of Canada, it is subject to the laws of the country in which it is located. Those laws may require

disclosure of your Personal Information to authorities in that country. For written information about our policies

and practices regarding service providers outside of Canada, contact our Privacy Officer using at the contact

information in the “How to Contact Us” section below.

Third Party Services

Frank Mortgage services may allow you to access services provided by others and to interact with other service

providers. These services provided by others are subject to the privacy practices of the third-party service provider

and are governed by their privacy policies and policies, not those of Frank Mortgage. We may also provide links to

third party websites for your convenience and information. This Privacy Policy does not extend to any services,

products or websites provided by third parties. We do not assume responsibility for the privacy practices of such

third parties, and we encourage you to review all third party privacy policies prior to using third party services,

products or websites.

How to Contact Us

All comments, questions, concerns or complaints regarding your Personal Information or our privacy practices

should be sent to our Privacy Officer as follows:

Address: Attention: Privacy Officer

Frank Fintech Inc.

2300 Yonge St., #1600

Toronto, ON M4P 1E4

By e-mail: support@frankmortgage.com