Last Updated: October 6th, 2021
knnct respects and upholds individual rights to privacy and the protection of personal information. We know how important it is to protect your personal information and want to make every customer experience safe and secure. In keeping with that goal, we have developed this Policy to explain our practices for the collection, use, and disclosure of your personal information.
“Personal Information” means information about an identifiable individual, including, for example, an individual’s name, address, telephone number(s), whether you are acting as a Broker and/or Lender, license to operate as a Broker or Lender including the Broker or Lender’s registration or license number, Broker’s or Lender’s email address and business name and address, that alone or when in combination with other information may be used to readily identify, contact, or locate you. We do not consider Personal Information to include information that has been anonymized so that it does not allow a third-party to easily identify a specific individual.
COLLECTION AND USE OF PERSONAL AND NON-PERSONAL INFORMATION.
We collect information, including Personal Information, when you:
• Register to use the Service;
• Log in with social networking credentials (if available);
• Use the Service and communicate with us.
When you visit knnct Platform, you provide us with two types of information: personal information you knowingly choose to disclose that is collected by us and non-personal information collected by us as you interact with our Services.
The types of information we collect depend on the nature of your interaction with us:
We may collect personal information such as:
• Account Information: To create an account with knnct, you may be required to provide some information about yourself, including but not limited to your email address, your license or registration number (if applicable), name, whether you are a Broker and/or a Lender, business name, address, telephone number, password, and other information. You will be providing this information directly to us.
• Other Information: You may provide other information directly to us. For example, we collect information when you fill out a form or mortgage application, fill in your lending criteria, fill in a the information regarding mortgages for sale, filter results of Mortgage Deals or Mortgage Assets, complete a survey or review, participate in a contest or promotion, communicate with us via third-party social media sites, request customer support or otherwise communicate with us. Providing this information is voluntary and not required to use the Services.
You may choose not to provide us with your Personal Information. However, if you make this choice, we may not be able to provide you with the Service, or information that you requested. For example, we require your email address in order to verify your account, which is necessary so that notifications may be sent to you electronically. In addition, we require your license number to verify that you are authorized to operate as either Lender and/or Broker and to confirm your entitlement to use the knnct Platform and Services. Should you no longer wish to receive notifications from knnct when you receive a message from another knnct Member, you may notify knnct by email that you wish to opt out of receiving these types of messages or turn these notifications off through the Application Settings. knnct will not send you notifications after your account is deleted.
Non-personal information does not identify you as an individual. When you visit and use the Services, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Service may not work properly or as well as it might otherwise.
• We may collect non-personal information such as:
• Usage Information: We collect information about your use of the Services, including Mortgage Deals, Mortgage Assets, Posting, successful transactions and Mortgage Deals and/or Mortgage Assets viewed, Member interactions and other information about your interactions with us, other Members, the Services and other users.
• Device Information: We collect information about the computer or mobile device you use to access our services, which may include the hardware model, operating system and version, browser type and language, IP address, unique device identifiers and mobile network information.
• Location Information: We may collect information about the location of your device each time you post or view a Mortgage Deal or Posting through knnct Platform, access or use one of our mobile applications including the knnct App, or otherwise consent to the collection of this information.
• Non-Specific Mortgage Deal Information: We may collect general information about the Mortgage Deals posted on the knnct Platform relating to location, amount of mortgage loan sought, type of mortgage sought, applicant’s beacon score, loan-to-value percentage and any other data or information or Mortgage Assets posted on the knnct Platform relating to location, number of mortgages to be sold, currency of any proposed transaction, type of mortgages being sold, average beacon score, average loan-to-value percentage and any other data or information that allow us to gain a better understand of the mortgage marketplace (both mortgage origination as well as mortgage sales) operating in the jurisdiction where you operate.
• Non-Specific Lender and Lending Criteria Information: We may collect general information about the Lenders or lending criteria of such Lender using, or accessing Mortgage Deals, on the knnct Platform relating to location, amount of mortgage loan willing to provide, types of mortgage willing to fund, successful applicant’s beacon score, loan-to-value percentage information about the Lenders posting Mortgage Assets for sale or criteria of Lender using, or accessing Mortgage Assets, location, number of mortgages to be sold, currency of any proposed transaction, type of mortgages being sold, average beacon score, average loan-to-value percentage and any other data or information that allow us to gain a better understand of the mortgage marketplace (both mortgage origination as well as mortgage sales) operating in the jurisdiction where you operate.
INFORMATION WE COLLECT FROM OTHER SOURCES.
We may also obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you (or Mortgage Deal owners or the consummation of Mortgage Asset transactions) from third parties, including but not limited to identity or license verification services, mailing list providers and publicly available sources.
We also combine data and information we collect from other users with information (including publicly sourced data and information) we have collected about you. For example, if another user imports his or her address book or contacts from another site or service, we may merge that information with information we have collected about you.
USE OF INFORMATION.
knnct uses Personal Information (including search criteria, Identity Information and Financial Information) and non-Personal Information for the following general purposes:
- To operate, maintain and make available the knnct Platform and improve our Services.
- To connect Lenders and Brokers to facilitate mortgage transactions either by way of a Lender entering into a mortgage agreement with a Client (or client of a Client) or Lender purchasing or acquiring all or a portion of an existing Mortgage Assets from another Lender.
- To verify that a Lender and/or Broker is properly authorized to act as Lender and/or Broker in the jurisdiction where the Lender and/or Broker is operating or where the mortgage assets are located;
- To develop a deeper understanding and insights as to current and long-term mortgage market trends about Brokers, Lenders and other using the knnct Platform;
- For billing, identification and authentication, and fraud prevention.
- To analyze Services and improve features and functionalities of the knnct Platform, our products and the knnct Platform generally.
- To contact you and deliver administrative and technical notices, updates, security alerts, marketing notifications and offers and communications relevant to your use of our products and Knnct Platform via email, SMS, and push notifications.
- To provide you with customer support.
- For internal market research, troubleshooting problems, and detecting and protecting against error, fraud or other criminal activity.
- To enforce our Terms and Conditions and Service Agreement.
- As required by law or to comply with legal obligations such as law enforcement, courts orders, subpoena, or other situation where the law in a jurisdiction we operate in requires such.
- As otherwise set forth in the Policy.
Email or Cell Phone Numbers. knnct may use your email or cell phone number to contact you or call or text you in order to provide you notifications about notifications that you have received correspondence from another member about a Posting, tasks, for marketing purposes and to administer the knnct Platform. You can opt out of receiving certain promotional communications from knnct sent via text message at any time by following the instructions provided in text messages from knnct to text the word, “STOP”. Please note that your opt-out is limited to the phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, knnct may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or knnct’s ongoing business relations.
Financial Information. We use Financial Information solely as authorized by you in accordance with the knnct Platform. To keep your financial data secure, we do not store full credit card information on our servers. We may contract with a third party to process your payment card information. We also verify as to whether transactions involving Mortgage Assets have been consummated and the value of the Mortgage Assets that have been sold and purchased.
WHERE INFORMATION IS STORED AND PROCESSED.
knnct is based in the Canada but the information we collect is governed by laws of the country where such Data and information is created and that Data and information is stored in that country in accordance with the rules and regulations of that country. By accessing or using the Services or otherwise providing information to us, all non-Canadian users consent to the processing and transfer of information in and to Canada.
SHARING OF INFORMATION.
- With vendors, venues, consultants and other service providers who need access to such information to carry out work on our behalf;
- With third parties such as venues and event planners that we partner with for their own services and marketing purposes;
- In response to a request for information in legal obligations (including, without limitation, regulators and legislators that govern the mortgage and financial sectors and the parties that operate in those sectors). knnct may disclose Personal Information, including location data, communication data or data analyzing the number of views of a Mortgage Deal or Posting, to a third party if required to do so by law or pursuant to a warrant or subpoena or as otherwise required by any applicable foreign or domestic law, rule or regulation;
- If we believe your actions are inconsistent with our user agreements or policies, or to protect our rights, or the rights of Members, and safety of knnct or others;
- With your consent or at your direction.
knnct does not share or sell Personal Information to third party vendors.
DELETION OF ANNONYMOUS OR AGGREGATED DATA.
knnct collects, stores, analyzes, reviews for trends and shares certain data about the use of Services on an aggregate and/or anonymous basis. knnct does not link this information to anything personally identifiable to you if shared with third parties.
DELETION OF PERSONAL INFORMATION
knnct recognizes the importance of each Client’s personal information and data of personal data and knnct will erase and to prevent processing in following specific circumstances:
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed – for example, after a reasonable period of time following either a Broker accepting an offer from a Lender or the expected closing date of any proposed transaction;
- When the individual withdraws consent;
- When the individual objects to the processing and there is no other legal ground for the relevant processing activity;
- When the personal data was unlawfully processed;
- Where the personal data has to be erased in order to comply with a legal obligation.
What information does knnct retain?
The knnct platform stores data about Brokers and Lenders that are subscribers to the knnct platform. We store the name, e-mail address, gender, organisation/department (if provided) and transactions (in the case of Brokers, mortgage deals posted or Lender offers accepted or declined and, in the case of Lenders, any deals considered or offers made to Brokers whether such offer is accepted or declined) in order to create a report, which is stored on our secure servers in country where the Brokers and/or Lenders reside for a period of 90 days. This data is stored and used in accordance with our Terms and Conditions which can be found at: www.knnct.com/termsofservice.
If consent is provided, personal data (including the above, plus address, telephone number and notes) may be stored in our CRM system for the purposes of contacting you regarding knnct updates, news, products and promotions.
How can data be deleted?
If you are a Broker or Lender using the knnct platform, knnct acts as data controller. In this case, we will delete personal information about you upon request (via email to email@example.com), upon the closure of your account, or after three years.
Data may still remain in the systems back-up files, which will be deleted periodically.
Information may be deleted from our CRM upon request to firstname.lastname@example.org. We undertake to perform the deletion within one month (30 calendar days) and will send you a confirmation once the information has been deleted. Wherever possible, we will aim to complete the request in advance of the deadline.
SOCIAL SHARING FEATURES.
The Services may offer social following or sharing features and other integrated tools (such as the Facebook “Follow” or “Like” button), which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
You may opt-out of receiving communications from us and our partners by unsubscribing to email notifications or simply changing your settings for the knnct Platform. You can also remove your information from our database and choose to not receive future communications related to the knnct Platform by cancelling your account. If you wish to deactivate your account, please contact us at email@example.com .
The mortgage industry, regardless of location, is highly regulated and there are a significant number of rules and regulations that govern the industry and actions and activities of Brokers and Lenders. knnct collects, retains, and use information regarding its Members, the Mortgage Deals and Postings and all data, information and documents created by Brokers (including any amendments) and accessed and uploaded by a Client to the knnct cloud server. Knnct makes all such information available to regulatory bodies that govern the mortgage industry as and when properly requested to the extent that the location of the Mortgage Deal, Posting, Mortgage Assets or Member is relevant to such regulatory body. In addition, knnct maintains and retains in secure storage all such information specifically as a record for its own purposes and so that is able to comply if it is properly requested to provide such documents to relevant regulatory bodies.
PRIVACY OF MINORS.
Members are obligated under the Terms and Conditions to be at least 18 years of age. We do not knowingly collect, maintain, or use Personal Information from minors under 18 years of age, and no part of the Service is directed to minors under the age of 18. If you learn that your child has provided us with Personal Information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected any Personal Information from individuals under 18 years of age, we will promptly take steps to delete such information and terminate the minor’s account.
CALIFORNIA PRIVACY RIGHTS.
California’s “Shine the Light” law permits users in California that are also California residents to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California users certain information upon request or permit California users to opt in to, or opt out of, this type of sharing. knnct may share personal information as defined by California’s “Shine the Light” law with third parties or affiliates for such third parties’ or affiliates’ own direct marketing purposes. California residents may obtain information about our compliance with this law by sending us an email request to email@example.com. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, California, and zip code. Please note that knnct is not required to respond to requests made by means other than through the provided email address.
CHANGING, REMOVING AND UPDATING YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION.
NOTIFICATION OF CHANGES.
If you have any questions about this privacy statement, the practices of Services, or your dealings with the knnct Platform, you may contact us at firstname.lastname@example.org.