At Roxborough Capital, protecting the privacy of our clients, partners, and website visitors is a responsibility we take seriously. We are committed to maintaining the accuracy, confidentiality, security, and integrity of all personal information entrusted to us. Our Privacy Policy reflects our ongoing dedication to safeguarding your information and ensuring transparency in how it is collected, used, and protected.

Website Information

The content provided on our website is intended for general informational purposes only. While Roxborough Capital makes every reasonable effort to ensure the information presented is accurate and current, we cannot guarantee complete accuracy, as market conditions, lending guidelines, and individual financial circumstances may change over time.

Accordingly, Roxborough Capital assumes no liability for any loss or damages resulting from reliance on information contained on this website. Visitors are encouraged to seek professional advice tailored to their individual financial situation before making mortgage or lending decisions.

Collection of Personal Information

In the course of providing mortgage and financial services, Roxborough Capital may collect personal information with your knowledge and consent. Personal information refers to information about an identifiable individual and may include, but is not limited to:

• Full name and contact details
• Residential address
• Age and date of birth
• Employment and income information
• Credit history and financial records
• Banking and payment information
• Personal preferences relevant to financing needs
• Family or household financial information where applicable

This information is collected solely for the purpose of assessing, arranging, and managing mortgage and financing solutions that best meet our clients' needs.

Use and Disclosure of Information

To provide our services effectively, Roxborough Capital may share relevant personal information, where required and with appropriate safeguards, with trusted third parties directly involved in the mortgage process, including:

• Credit reporting agencies
• Financial institutions and lenders
• Mortgage insurers
• Legal and regulatory professionals
• Service providers and vendors supporting the transaction process

Any sharing of information is conducted in accordance with applicable privacy laws and only to the extent necessary to facilitate the services requested by our clients.

Our Commitment

At Roxborough Capital, we continually review our privacy practices to ensure your personal information remains protected through secure systems, strict confidentiality standards, and responsible information handling procedures. Your trust is important to us, and we remain committed to protecting your privacy at every stage of your financial journey.

Our Privacy Policy is based on, and complies with, Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA"), which includes the Ten Privacy Principles outlined in the Canadian Standards Association Model Code for the Protection of Personal Privacy. For more information about this legislation, please visit the official website of the Office of the Privacy Commissioner of Canada at priv.gc.ca.

This Privacy Policy describes the ten principles that we follow to ensure that we protect your Personal Information when we collect, use, or disclose it in the course of carrying on commercial activities in Canada. All our employees who have access to Personal Information must adhere to our Privacy Policy and related procedures.

The Ten Principles of Privacy

The following ten principles govern our actions as they relate to the use of Personal Information:

Information We Collect

At Roxborough Capital, we collect and use personal information to provide the products and services you request and to ensure we continue meeting your financial needs effectively. The information we gather allows us to assess your circumstances, deliver tailored mortgage and lending solutions, and maintain an exceptional level of service throughout your financial journey.

From time to time, with your consent, we may also use your personal information to keep you informed about new services, financial solutions, market updates, or additional offerings that may be relevant to your needs.

When you visit our website, we do not collect personally identifiable information unless you voluntarily provide it through inquiries, forms, or communications submitted directly to us. Any personal information shared with us is treated with strict confidentiality. This Privacy Policy does not apply to anonymized or aggregated statistical information that cannot be used to identify any individual. Roxborough Capital reserves the right to use aggregated, non-identifiable data for analytical, operational, and business development purposes.

How We Use Your Information

Personal information collected by Roxborough Capital is generally used for the following purposes:

• Client Communication: To communicate with you regarding mortgage products, services, updates, and support.
• Transaction Processing: To prepare, review, and process documentation related to your financing or mortgage transaction.
• Service Enhancement: To evaluate service quality, monitor transaction progress, and improve the client experience through feedback and performance review.

We only use personal information for the purposes disclosed to you at the time of collection. Should we require your information for any additional purpose, we will notify you and obtain your consent before proceeding.

Disclosure of Personal Information

Your privacy is important to us, and Roxborough Capital maintains strict confidentiality standards. We will only disclose your personal information under the following circumstances:

With Your Authorization

Many of the services we provide require access to personal and financial information in order to properly assess and arrange financing solutions on your behalf. In all such cases, your consent will be obtained before collecting, using, or sharing your information. We will never use your information for purposes beyond those communicated to you.

You may withdraw your consent at any time, subject to legal, contractual, or regulatory obligations. Please note that limiting consent may affect our ability to continue providing certain products or services.

When Required by Law

In certain circumstances, Roxborough Capital may be legally required to disclose personal information, including obligations related to taxation, regulatory compliance, court orders, or lawful government requests. In such instances, only the information specifically required by law will be disclosed.

When Permitted by Law

Privacy legislation may permit disclosure without consent in limited situations, such as fraud prevention, debt recovery, emergencies involving health or safety, or where unlawful activity is suspected. Any disclosure made under these provisions will be handled responsibly and in accordance with applicable law.

Security & Safeguards

Protecting client information is a top priority at Roxborough Capital. We maintain robust safeguards designed to prevent loss, theft, unauthorized access, misuse, disclosure, copying, or alteration of personal information entrusted to us. Our security measures include:

• Secure physical storage and restricted office access
• Encrypted electronic systems and cybersecurity protections
• Secure document disposal and confidential shredding practices
• Internal privacy protocols and staff confidentiality standards
• Contractual safeguards with trusted third-party service providers handling data on our behalf

We continually review and strengthen our security practices to meet evolving privacy and compliance standards.

Accessing or Updating Your Information

You have the right to request access to the personal information we maintain about you and to request corrections if any information is incomplete, inaccurate, or outdated.

Requests for access or updates may be submitted in writing to our Privacy & Compliance Officer, and we will respond within a reasonable timeframe in accordance with applicable privacy legislation.

Marketing & Communication Preferences

With your consent, Roxborough Capital may contact you regarding services, market insights, financing opportunities, newsletters, or relevant updates that may benefit you. You may opt out of promotional communications at any time by contacting us directly.

Your communication preferences will always be respected, and opting out of marketing communications will not affect transactional or service-related communications regarding your active account or mortgage file.

Website Usage

Our website may include links to third-party websites that operate independently and are not governed by this Privacy Policy. We encourage visitors to review the privacy practices of any external sites they access.

Like most commercial websites, Roxborough Capital may collect general website usage data, including traffic patterns, browsing activity, and performance analytics, to improve website functionality and user experience. This information is collected in aggregate form and does not identify individual users.

Communication Security

We use various communication channels, including phone, secure online platforms, and email, to serve our clients efficiently. While we use industry-standard encryption and security practices where appropriate, electronic communications may still carry inherent risks.

Clients who prefer alternative communication methods may request accommodations by contacting our Privacy & Compliance Office.

Anti-Spam Compliance

Roxborough Capital is committed to full compliance with Canada's Anti-Spam Legislation (CASL). We may periodically send communications such as newsletters, market updates, educational content, and company announcements that may qualify as commercial electronic messages. These communications will only be sent with your consent, and you may unsubscribe at any time.

Protection & Retention of Information

We take reasonable and appropriate steps to safeguard all documentation and information supplied by clients. Records are securely stored, retained only as required by law or business necessity, and confidentially destroyed when no longer needed.

Client information remains protected under the stewardship of Roxborough Capital, and access is limited strictly to authorized personnel and approved service providers involved in delivering your requested services. Unauthorized access, retention, or use of client information is strictly prohibited.