Contents
Section 1
Who We Are
ClosingDesk Technologies Inc. ("ClosingDesk", "we", "us", or "our") is a federally incorporated Canadian company (incorporated June 29, 2026 under the Canada Business Corporations Act). We are building a secure, broker-branded mortgage portal designed for Canadian mortgage brokers and their clients.
Our registered address and primary place of business is in Canada. Our digital services are accessible at closingdesk.ca and closingdesk.app.
This Privacy Policy applies to all personal information we collect through our website, early access waitlist, and any future services we operate. It is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, Quebec's Act Respecting the Protection of Personal Information in the Private Sector (Law 25) and other applicable Canadian provincial privacy laws.
Section 2
Information We Collect
2.1 Information You Provide Directly
When you sign up for early access to ClosingDesk, we collect the following personal information:
| Information | Why We Collect It |
|---|---|
| First and last name | To address you personally in communications |
| Work email address | To send you early access updates and communicate with you |
| Brokerage name | To understand your professional context and tailor our outreach |
| Province of operation | To ensure compliance with applicable provincial regulations and to understand our market |
| Approximate deal volume per month | To understand your practice and prioritize early access appropriately |
We do not collect payment information, government identification, social insurance numbers, mortgage documents, or any other sensitive financial data at this stage of our operations.
2.2 Information We Collect Automatically
When you visit closingdesk.ca, we may automatically collect limited technical information including:
- Your IP address and approximate geographic location (country/province level)
- Browser type and version
- Device type (desktop, mobile, tablet)
- Pages visited and time spent on our site
- Referring URL (which website sent you to ours)
- Date and time of your visit
This information is collected to understand how our website is used and to improve your experience. It is not used to identify you personally unless combined with information you have voluntarily provided.
2.3 Information We Do Not Collect
We want to be explicit about what we do not collect at this stage:
- Mortgage documents or financial records of any kind
- Client personal information belonging to broker clients
- Credit bureau data or financial history
- Payment card or banking information
- Government-issued identification numbers
- Biometric data of any kind
Section 3
How We Use Your Information
We use your personal information only for the purposes for which it was collected, and only in ways that a reasonable person would consider appropriate in the circumstances. Specifically:
3.1 Early Access Communications
We use your name and email address to send you updates about ClosingDesk's development, early access availability, and relevant news about our platform. You consented to this when you submitted the early access form. Every communication we send includes an unsubscribe option.
3.2 Personal Outreach
We use your name, brokerage, province, and deal volume to have meaningful conversations with you about your practice and how ClosingDesk can help. This information allows us to reach out to you personally rather than sending generic mass communications.
3.3 Product Development
Aggregate, anonymized information about the types of brokers who sign up (by province, deal volume, and brokerage size) helps us prioritize which features to build first and which markets to focus on. We do not use your individual information in ways that identify you for this purpose.
3.4 Legal and Compliance Obligations
We may use or retain your information to comply with applicable laws, regulations, or legal processes, or to protect the rights and safety of ClosingDesk, our users, and the public.
3.5 What We Will Never Do
- Sell your personal information to any third party — ever
- Share your information with advertisers or data brokers
- Use your information for automated decision-making that affects your rights
- Send you marketing communications from third parties
- Use your information in ways not described in this policy without first obtaining your consent
Section 4
Legal Basis for Processing
Under PIPEDA and applicable Canadian privacy law, we collect and use your personal information based on the following grounds:
4.1 Consent
When you submit our early access form, you are providing express consent for us to collect and use your personal information for the purposes described in this policy. Your consent is voluntary. You may withdraw it at any time by contacting us or clicking the unsubscribe link in any email we send you.
4.2 Legitimate Interests
We have a legitimate interest in understanding the market we serve and in communicating with people who have expressed interest in our product. We balance this interest against your privacy rights and will never use it to override your preferences or to engage in practices that would be unexpected or harmful to you.
4.3 Legal Obligation
In limited circumstances, we may need to process your personal information to comply with a legal obligation, such as a court order or regulatory requirement.
Section 6
Data Storage and Security
6.1 Where Your Data Is Stored
Your early access information (name, email, brokerage, province, deal volume) is currently stored by Loops, our email communication platform, on servers located in the United States. Our website is hosted on Vercel's infrastructure.
As ClosingDesk's mortgage portal product is developed, all mortgage-related data and sensitive client information will be stored exclusively on Canadian servers (AWS Canada Central, located in Montreal, Quebec) in compliance with PIPEDA and Quebec Law 25.
6.2 Security Measures
We take the security of your personal information seriously. Current security measures include:
- All data transmitted to and from our website is encrypted using TLS 1.3
- Our website is served exclusively over HTTPS with HSTS enforced
- Access to any stored data is restricted to authorized personnel only
- Our email platform (Loops) maintains industry-standard security certifications
- We use Cloudflare for DDoS protection and security monitoring
- Multi-factor authentication is required for all internal systems
No method of transmission or storage is 100% secure. While we implement reasonable safeguards, we cannot guarantee absolute security. In the event of a data breach that poses a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada as required by law.
6.3 Breach Response
ClosingDesk maintains a breach response plan. In the event of a security incident involving your personal information, we will:
- Assess the nature and scope of the breach as quickly as possible
- Take immediate steps to contain and remediate the incident
- Notify the Office of the Privacy Commissioner of Canada if required
- Notify affected individuals directly if there is a real risk of significant harm
- Document the breach and our response in our internal records
Section 7
Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law.
| Data Type | Retention Period | Reason |
|---|---|---|
| Early access signup information | Until you unsubscribe or request deletion, or 2 years from last activity — whichever comes first | To maintain our early access list and communicate with interested brokers |
| Email communication records | 2 years from last activity | For communication history and legal protection |
| Website usage data (logs) | 90 days | Operational troubleshooting only |
| Unsubscribe records | Indefinitely | To honour your opt-out and comply with CASL |
When personal information is no longer needed, it is securely deleted or anonymized so that it can no longer be associated with you.
Section 8
Your Privacy Rights
Under PIPEDA and applicable Canadian privacy legislation, you have the following rights with respect to your personal information:
Right to Access
You have the right to request access to the personal information we hold about you, including information about how it is being used and with whom it has been shared. We will respond to access requests within 30 days.
Right to Correction
If you believe the personal information we hold about you is inaccurate or incomplete, you have the right to request that we correct it. Simply email us at the address below with the correct information.
Right to Withdrawal of Consent
You may withdraw your consent to our use of your personal information at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before the withdrawal. To withdraw consent, you may:
- Click the unsubscribe link in any email we send you
- Email us directly at [email protected]
Right to Deletion
You may request that we delete your personal information. We will honour deletion requests promptly, subject to any legal obligations we have to retain certain records. We will confirm deletion in writing within 30 days of your request.
Right to Lodge a Complaint
If you believe we have mishandled your personal information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada:
- Website: priv.gc.ca
- Phone: 1-800-282-1376
- Mail: 30 Victoria Street, Gatineau, Quebec K1A 1H3
We encourage you to contact us first so we have an opportunity to address your concerns before you escalate to the Commissioner's office.
Quebec Residents — Additional Rights Under Law 25
If you are a resident of Quebec, you have additional rights under the Act Respecting the Protection of Personal Information in the Private Sector (Law 25), including the right to data portability and the right to request that automated decisions be reviewed by a human. Please contact our Privacy Officer to exercise these rights.
Section 9
Cookies and Tracking
9.1 What Are Cookies
Cookies are small text files placed on your device when you visit a website. They help websites remember your preferences and understand how you use them.
9.2 How We Use Cookies
Currently, closingdesk.ca uses minimal cookies. Specifically:
- Essential cookies: Required for the website to function, including security and session management. These cannot be disabled.
- Analytics cookies: We may use anonymized analytics to understand how visitors use our website (for example, which pages are most visited). No personally identifiable information is collected through analytics.
We do not currently use advertising cookies, tracking pixels, or cross-site tracking technologies.
9.3 Your Cookie Choices
You can control cookies through your browser settings. Disabling cookies may affect the functionality of our website. Most browsers allow you to refuse cookies or delete existing ones — refer to your browser's help documentation for instructions.
9.4 Email Tracking
Emails we send through Loops may include open tracking and link click tracking, which is standard practice for email communications. This helps us understand which emails are useful and which are not. You can disable image loading in your email client to prevent open tracking.
Section 10
Children's Privacy
ClosingDesk is a professional platform designed for licensed mortgage brokers and is not intended for use by anyone under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 18, we will delete it promptly. If you believe we may have collected information from a child, please contact us immediately at [email protected].
Section 11
Changes to This Policy
We will update this Privacy Policy as our business and products evolve — particularly when we launch our mortgage portal product, which will involve significantly more personal information. We commit to the following when we make changes:
- We will update the effective date at the top of this policy
- For material changes, we will notify you by email at least 30 days before the changes take effect
- For significant changes that affect how we use your information, we will seek fresh consent where required by law
- We will maintain a record of previous policy versions available upon request
We encourage you to review this policy periodically. Your continued use of our services after changes take effect constitutes acceptance of the updated policy, except where fresh consent is required.
Section 12
Contact Us
If you have any questions, concerns, or requests related to this Privacy Policy or how we handle your personal information, please contact our Privacy Officer:
Privacy Officer — ClosingDesk Technologies Inc.
Ryan Haslett
Founder & CEO, ClosingDesk Technologies Inc.
We aim to respond to all privacy inquiries within 30 days. For urgent matters, please indicate the urgency in your subject line.
If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at priv.gc.ca or by calling 1-800-282-1376.