WELCOME

This Privacy Policy has been prepared by Murabaha Inc. o/a Manzil and sets out the manner in which we collect, use, disclose, and otherwise process personal information in connection with the www.manzil.ca website (the “Website”), through Manzil’s Halal financing and investment products, and through our other interactions with you.

Please note that our Manzil mortgage product may not be available in your jurisdiction, including Quebec.

COLLECTION AND USE OF PERSONAL INFORMATION

Manzil Financing Account Creation: When you apply for a Manzil mortgage, you will first be required to create an online account and provide personal information, including: first and last name, date of birth, mailing address, information about your current property (including whether you own it and how long you have lived there), whether you are a Canadian citizen, email address, phone number and a password that you create. We use this information in order to create and administer an online account for you to provide and access information about your application.We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).

Manzil Financing Application: When you apply for a Manzil mortgage, we collect the following additional information:

1. Employment information, including employer, job, length, and nature of employment, and employment references with your consent;

2. Financial information, including estimated income, investment property information (including address, estimated value, mortgage balance, monthly payments), information about your investment accounts, total credit card and line of credit debt and monthly payments, outstanding loans and monthly payments;

3. Mortgage information, including mortgage type, target property location, purchase price, down payment, sources of down payment, and target closing date.

4. If you are applying with a co-applicant, we also collect information about the co-applicant such as name, email address and phone number, as well as verification information (as set out below). We rely on you to ensure you have obtained consent to provide this information to us.

5. Once you are pre-approved for a mortgage, we collect verification information for you and your co-applicant (if applicable), including proof of income, down payment and bank account verification. We may offer you the option to verify this information by logging in to your bank account through a third-party integration partner (we do not receive your logon credentials) and authorizing our partner to collect certain transaction data that will be used to verify the information you have provided to us (for example, to verify that your income deposits match what you have told us). However, this form of verification is optional and you can also provide us with verification through alternate means, such as recent pay stubs and, void check and letter of employment.We may also ask you to provide additional documents to verify the information you have provided in your application including government-issued identification, property tax bill, utility bill, last notice of assessment.

We use this information to assess your application and determine your eligibility for financing, to meet our legal and regulatory requirements, detect, and prevent fraud and other unauthorized or illegal activities, and as otherwise permitted or required by applicable law. If you are approved, we also use this information for the purposes of opening, administering, servicing, funding and enforcing your Manzil mortgage, including collecting outstanding debts.

Credit Reports: If you are pre-approved for a Manzil Mortgage, we will obtain your consent to use your personal information (first and last name, date of birth, mailing address) in order to obtain your credit score and/or credit report from Equifax or another consumer reporting agency. Your credit report may include information such as the types and amounts of credit advanced to you, payment histories, negative banking items, collection actions, legal proceedings, previous bankruptcies and other information reported by your creditors. We use this information in order to help us determine your eligibility for a mortgage. We may also request your social insurance number on an optional basis. You are not required to provide your social insurance number. However, if you choose to provide it, we use it to assist us in identifying you with credit reporting agencies and for internal fraud prevention purposes. Manzil will exchange personal information with credit bureaus as necessary at the time of your application and throughout the term of your Mortgage Agreement in order to review and verify your ongoing creditworthiness and manage and assess our risks. You authorize credit bureaus to provide such information to us.

Manzil Funds: If you would like to invest in our Manzil Mortgage Investment Fund, you will be required to register and open an account with our third-party investment partner. With your consent, we may provide your contact information to our investment partner so that they may contact you. Personal information collected by our investment partner will be treated in accordance with their privacy policy, which we recommend you review. We will receive information about you and your investments from our investment partners in order to assess the performance of your investments and the Manzil Fund, process your requests, and meet our regulatory requirements. This includes information about your investment activity, the amount of funds invested in your account, frequency with which funds are deposited into your account, withdrawals from your account, and information about the performance of your investment, including rate of growth. We rely on our investment partners to ensure they obtain your consent to provide this information to us.
Marketing Communications: We may obtain your consent to use your information to send you communications by mail, email or telephone marketing or promoting products and services that may be of interest to you. You can opt-out of receiving marketing offers at any time by clicking on the unsubscribe link included in our marketing email communications or by contacting us as set out under Contact Us below. Please note that you may continue to receive certain transactional or informational electronic communications from us.

Call Recording: We may monitor and record our telephone conversations with you for training and quality assurance purposes. You will be provided with a notice at the beginning of any call that is being recorded. If you do not wish to have your call recorded, please let us know.

Customer Service: When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service and product and service offerings. We also use personal information to establish and manage our relationship with you and provide quality customer service.

Employment: In connection with a job application or related inquiry, you may provide us certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). This information will be used for the purpose of processing and responding to your application for current and future career opportunities.
Survey and Customer Research:From time to time, we may offer you the opportunity to participate in one of our surveys or other customer research. The information obtained through our surveys and customer research is used in an aggregated, non-personally identifiable form to help us understand our customers and to enhance our product and service offerings.

Contests and Promotions: When you enter a contest or participate in a promotion, we may collect your name, address, phone number, email address, and other information you provide. This information is used to administer your participation in the contest, sweepstakes or promotion.

HOW PERSONAL INFORMATION IS COLLECTED

We collect personal information directly from you (such as information you provide to us through your online account in connection with your application for a Manzil Mortgage, or information from your use of our services and Website) as well as from third parties such as our investment partners (as described above), appraisers, credit bureaus, financial institutions, current or former employers,

DISCLOSURE OF PERSONAL INFORMATION

We will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out herein.

Service Providers: Your personal information may be transferred (or otherwise made available) to our subsidiaries, affiliates and other third parties who provide services on our behalf. Manzil uses service providers to process payments (where applicable),send communications, verify information you have provided to us, host the Website, operate certain of its features such as forms and user interfaces, send communications, or manage and analyze data and our advertising effectiveness. Your personal information may be maintained and processed by Manzil and its third party service providers in the US, Canada, or other jurisdictions. In the event personal information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws. Service providers are given the information they need to perform their designated functions, and are not authorized to use or disclose personal information for their own marketing or other purposes.

Investors: Manzil Mortgages are funded through capital provided by our investors.Information about current and former mortgage customers will be shared on a non-identifiable basis with current as well as potential investors. The information provided to investors includes aggregated data derived from customer credit history data and mortgage performance information. The information is presented in a manner that the identity of an individual would not be identifiable from the data. We share this information in order to allow current and potential investors to evaluate the performance of the loans. For example, the data may be used to determine default and delinquency rates, or to present aggregate information on creditworthiness.

Appraisers: Manzil relies on the valuation expertise of a third-party mortgage appraiser to determine the value of your target property. Manzil will share information about your target property to a third-party appraiser for the purpose of scheduling an in-person appraisal of the target property, and Manzil will collect a copy of the property appraisal.

Legal/Compliance: Manzil and its Canadian, US and other service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud or as otherwise required or permitted by applicable Canadian, US or other law. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.

Sale of Business: Personal information may be transferred as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Manzil or as part of a corporate reorganization or stock sale or other change in corporate control.
Cookies, Interest-Based Advertising, and Additional Information about our Website

VISITING OUR WEBSITE

In general, you can visit the Website without telling us who you are or submitting any personal information. However, we and/or our service providers (such as Google Analytics) collect IP (Internet protocol) addresses from all visitors to the Website and other related information such as page requests, browser type, operating system and average time spent on our Website. This information is used to help us understand our Website activity, and to monitor and improve the Website.

COOKIES, TRACER TAGS & WEB BEACONS

Our Website uses a technology called “cookies”. A cookie is a tiny element of data that our Website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. We use cookies on the pages on our Website where you are prompted to log in or that are customizable. If you have registered with our Website, these cookies (1) may let us know who you are, (2) may be necessary to access your account information, and (3) will provide us and our service providers with information that we will use to personalize our Website in accordance with your preferences.

You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the features of our Website.

Our Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our Website. These tracer tags are used to help us optimize and tailor our Website for you and other future visitors to our Website.
Analytics

This Site also uses web analytics services such as Google Analytics. They use cookies to help us analyze how visitors use the Website. For example, with Google Analytics, the information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by a Google server. Google uses this information for the purpose of evaluating your use of the Website, compiling reports on Website activity for Website operators, and providing Website operators with other services relating to Website activity and internet usage. You can prevent the storage of data relating to your use of the Website and created via the cookie (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en . You can also obtain additional information on Google Analytics’ collection and processing of data and data privacy and security at the following links:

https://policies.google.com/technologies/partner-sites and
https://support.google.com/analytics/topic/2919631

Interest-Based Advertising

We work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website and other websites and apps in order to provide you with tailored advertisements across the Internet. This is a common marketing practice referred to as interest-based or online behavioural advertising. These companies may collect information about your activity across your different devices on our Website and third-party websites and apps (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate our online advertising campaigns.

For more information and to understand your options and how you can opt-out of interest-based advertising, please see “Opting-out of Interest-Based Advertising” below.

Opting-out of Interest-Based Advertising:For more information about interest-based advertising on your desktop or mobile browser and to understand your options, including how you can opt-out of receiving interest-based ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada (DAAC) Self-Regulatory Program for Online Interest-Based Advertising, please visit the DAAC website at http://youradchoices.ca/choices .

Important Notes About your Opt-Out:

If you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us across the Internet, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.
Interest-based advertising opt-outs work by saving cookies in your browser that tell the various ad partners that you have opted-out. You must opt-out from each web browser from which you do not want interest-based advertising (and this may involve different devices, if you use more than one). If you delete or clear your browser’s cookies, you will need to opt-out again.

THIRD PARTY LINKS

Our Website may contain links to other sites that we do not own or operate, including social media websites. Also, links to our Website may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

SAFEGUARDS AND RETENTION

We maintain your personal information on a confidential basis on servers located in Canada and the United States. We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to your personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.
We have personal information retention processes designed to retain personal information of our customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements (which may extend beyond the end of your relationship with us).

ACCESS TO YOUR PERSONAL INFORMATION

You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access, updating and corrections of inaccuracies in personal information we have in our custody or control by emailing or writing to us at the contact information set out below. You may also update certain contact information through our online account portal. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

CHANGES TO THE PRIVACY POLICY

This Privacy Policy may be updated periodically to reflect changes to our personal information practices. We will post the updated Privacy Policy on our website. Your personal information will be treated in accordance with the Privacy Policy in place at the time your personal information was collected, unless you otherwise consent.

CONTACT US

Please contact our Privacy Officer if:

you have any questions or comments about this Privacy Policy,

you wish to access, update, and/or correct inaccuracies in your personal information, or

you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information.

You may contact our Privacy Officer: Mohamad Sawwaf by email at privacy@manzil.ca or by mail at the following address:
100 King Street West, Suite 6200Toronto, ONM5X 1A9