Accountability - Vivienda Housing and Mortgage Corp. ("Vivienda") recognizes the importance of privacy. Vivienda has a professional and an ethical obligation to keep all information it receives within a business relationship confidential, subject to a customer’s instructions and any applicable law. Vivienda manages the personal information of a customer in compliance with applicable legislation within the jurisdictions in which it conducts business. Vivienda reserves the right to periodically amend its privacy policy to update Vivienda's commitment to its customers, in accordance with current privacy laws.

Purpose of Collection - Personal information is any information that identifies an unincorporated customer. Business contact information, such as a business phone number or business office address, unless specifically advised that it is a home office, is not considered personal information, as it is considered to be on public record. Vivienda follows prudent business practices in collecting, using and disclosing personal information while providing its customers with products and services. Vivienda collects personal information to serve the reasonable business, product purchase and service needs and related needs of its customers. Vivienda requires this information to understand, access and assist its customers with their ongoing business, product purchase and service needs and to ensure that information is up-to-date.

Collection Methods - Vivienda collects information only by lawful and fair means. Whenever possible, Vivienda will collect personal information directly from a customer. Depending on the business services provided, Vivienda may obtain relevant information from other reasonable sources, with the consent of the customer. Address and method of payment information is collected to enable Vivienda to provide products and services to its customers.

Consent - Personal information will only be collected, used and disclosed with a customer's consent, except as required or permitted by law. A customer’s consent with respect to collection, use and disclosure may be in writing, verbal or implied as necessary to meet a customer's business, product purchase or service needs and Vivienda’s need to provide its products and services to a customer.

Disclosure Without Consent - In certain circumstances, Vivienda may disclose a customer’s personal information without their consent. Such circumstances include legal compulsion or authorization, required tax filings, and the reasonable apprehension or necessity to respond to an emergency that threatens life, health or security of an individual or the public. Disclosure may also occur if it is necessary to establish or collect payments due to Vivienda, or if the information is already publicly known.

Use of Personal Information - Vivienda uses personal information to provide products and services to its customers. Unless a customer consents, Vivienda will not disclose or sell a customer's personal or business contact information to any unrelated third party. When Vivienda releases information about a customer, it is done to serve specific needs, in the course of providing business services or products. With a customer's consent, Vivienda may provide information to Vivienda staff and agents for reasonable business purposes. Vivienda may also provide personal information to third parties providing services to Vivienda, provided the third party agrees to comply with Vivienda’s privacy policy and any applicable legislation.

Individual Access - A customer has the right to request a correction of the personal information that Vivienda holds about them. If during the course of a business relationship, any customer information changes, then a customer is requested to please inform Vivienda so that Vivienda can make the necessary changes. A customer may request access to the personal information Vivienda has regarding that customer, and Vivienda will respond to this request in a timely fashion. This request must be in writing and Vivienda will charge a reasonable fee for retrieval and copying. By law, Vivienda must deny access when a customer file contains personal information on a third party, and the information cannot be severed to maintain the third party's privacy. Vivienda may also deny access if a customer's information relates to existing or anticipated legal proceedings against the customer, including unpaid bills to Vivienda. If Vivienda denies a customer's request for access or correction, Vivienda will explain why. In all cases, Vivienda will attempt to mediate a resolution if possible.

Safeguards - In order to protect a customer's personal information, Vivienda will not collect, use or disclose a customer's personal information unless the purpose is identified or reasonably evident, such as for payment, collection or shipping purposes. Vivienda will also endeavor to maintain reasonable encryption, permissions and gateway safeguards on information accessible through Vivienda’s on-line payment processing system or database. Vivienda will keep a customer's personal information for only as long as necessary to fulfill the stated purpose or as required by law. Vivienda will maintain a customer's personal information as accurately as possible. In addition, Vivienda will keep a customer's personal information physically secure and protected by technological safeguards appropriate to the sensitivity of the information.