Privacy Policy

Last Updated: March 10, 2026

This privacy policy is intended to inform you about how personal information may be collected, used, and protected when you visit this site.

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0. Platform and Hosting

This website (https://www.alex-legault.com) is powered by the WelcomeSpaces platform, which enables professionals to create and manage their online presence. WelcomeSpaces provides the technical infrastructure, secure hosting, and some integrated communication tools (forms, appointment booking, chatbot, etc.).

To learn more about how WelcomeSpaces collects, uses, and protects personal information as part of its services, please consult their privacy policy: https://www.welcomespaces.io/privacy-policy.

The site owner remains responsible for the content published, any additional tools they may integrate, and complying with applicable personal information protection laws.

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1. Personal Information Protection Officer

Name: Alex Legault

Email: alex.legault@groupeorbis.com

Phone: (514) 464-2011

Postal Address: 1250, 1-204 Avenue de la Station, Shawinigan, Québec, G9N 1W8

The owner of this site may also appoint an additional officer depending on the services added or integrated. Please refer to the customized section at the end of this document.

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2. Personal Information Collected

By default, this site may collect certain personal information in the following cases:

• Contact form: Information voluntarily submitted (name, email, message, etc.).
• Appointment scheduling: Name, contact details, and relevant information needed to schedule a meeting.
• AI Chatbot: This site uses a virtual assistant powered by artificial intelligence.
  ➤ The personal information shared via the chatbot is not processed by the AI but is securely transmitted to private servers, where it is encrypted and protected.
  ➤ This information is only sent to the site owner in order to respond to you or provide follow-up

No automated analysis is performed on this data for advertising or profiling purposes.

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3. Cookies

By default, this site only uses strictly necessary cookies for:

• Proper site functionality (e.g., language management – NEXT_LOCALE) \
• Server load balancing (e.g., AWSALB, AWSALBCORS) \
• Storing your consent preferences if a cookie banner is enabled (CookieScriptConsent) \

These cookies do not personally identify visitors.

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4. Tools and Scripts Added by the Site Owner

The site owner may choose to add external tools, such as:

• Google Analytics or other tracking services
• Advertising pixels (e.g., Facebook Pixel, Google Ads, LinkedIn Insight)
• External appointment scheduling services (e.g., Calendly)
• Custom plugins or scripts

In such cases, the site owner is solely responsible for:

• Adding a cookie consent banner (CMP) if these tools place non-essential cookies.
• Updating the customized section below to describe the tools used and data collected.
• Complying with applicable personal information protection laws (Law 25, PIPEDA, GDPR if applicable).

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5. Data Retention and Hosting

Data is hosted on secure servers located in Canada or in jurisdictions that meet applicable legal requirements. It is retained for as long as necessary to fulfill the purposes for which it was collected.

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6. Your Rights

In accordance with Law 25 and PIPEDA, you have the right to:

• Access your personal information
• Correct or request the deletion of this information
• Withdraw your consent
• File a complaint with the Commission d’accès à l’information of Québec

To exercise these rights, please contact the designated officer listed in Section 1.

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7. Changes

This policy may be updated at any time to reflect changes in legislation or site practices. The most recent version will always be accessible at this address.

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8. Additional Information Provided by the Site Owner

The Orbis Mortgage Group commits to protecting the personal and confidential data of our clients, in accordance with government laws and as required by the Autorité des marchés financiers (AMF). As financial service providers, we have an obligation to protect the confidentiality of information received in the course of our duties. The purpose of this privacy policy is to inform our clients of the reasons we collect personal information, how we use it, the means used to protect it, and how to contact us if you have questions or concerns about privacy protection.

What is personal information?

We place great importance on the trust our clients place in us; that is why we protect confidentiality, private details, and information gathered in connection with their mortgage request, their pre-approval, information requests for a mortgage or loan, as well as insurance or any other product obtained through the Orbis Mortgage Group or its subsidiaries, provided by, or collected by, Orbis Mortgage Group and its staff or by Orbis brokers, its partners and subsidiaries on behalf of Orbis.

Why does the Orbis Mortgage Group collect personal information

The Orbis Mortgage Group collects and uses personal information for the following purposes:

• Provide mortgage brokerage services to the client and offer the products and services suited to their needs, including the granting and/or renewal of mortgages, creditors' group insurance, and other products offered and approved by the Orbis Mortgage Group or its subsidiaries, which may be of interest to the client;
• Verify the client’s credit file by inquiring with the credit bureau, as well as through personal information agents who hold information about the client’s financial position;
• Inform the client about their financial options, as well as ongoing market and mortgage industry developments;
• Audit services provided to our clients;
• Comply with municipal, provincial, federal laws and others; and
• For other specific purposes disclosed to the client by a member of the Orbis Mortgage Group before information collection; except where the law provides otherwise, we will use the client’s personal data for the sole purposes determined with the client. If personal information is required for another unlisted purpose, we will take all reasonable steps beforehand to ensure that the new purpose is identified before using it.

How do we collect your personal information?

The client profile is our main source of information. We therefore require their consent before seeking information from a third party, information that will help us determine the client’s eligibility and qualification for various products and services. For example, in the area of credit, it is essential for us to know their financial situation, as well as their credit file. After obtaining the client’s consent, we will contact other lenders, financial institutions, credit bureaus, and employers. Consent is very important, because without it we cannot perform the appropriate searches and, consequently, offer the credit product that meets the client’s needs. In most cases, consent is given directly on the form for a particular product or, on occasion, on a separate form. The consent declaration is clear and unambiguous, and in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA).

All representatives of the Orbis Mortgage Group must obtain the appropriate consent from each client applying for any credit facility. Failure to comply with this obligation could result in the suspension of access rights of all credit evaluation agencies such as Equifax, TransUnion and/or other companies offering similar services. Repeat offenders will be promptly reported to the appropriate regulatory authorities, which could have adverse consequences. An acceptable form of consent should include the consent form provided by Filogix System and/or Scarlet System. Moreover, if the application form is completed in Scarlet, the system may request consent at the end. It is imperative that the agent ensures it is on file. This form, or any other form compliant with PIPEDA standards, must be signed and approved by each client before we can access their credit report or any other information contrary to privacy protection law.

No access code to Equifax or any other credit reporting agency will be issued to a new member before a period of at least 60 days, and only after the Orbis Mortgage Group mentoring program has been successfully completed. The access code will be assigned to members who have been in the industry for at least 12 months and only after the head office has received at least three creditor references.

Consent

Providing information by the client to the Orbis Mortgage Group means they agree and consent to the Orbis Mortgage Group collecting, using, and disclosing these same personal information, in accordance with this privacy policy. The Orbis Mortgage Group will not collect, use, or disclose a client’s personal information without the necessary consent, except in certain extraordinary circumstances. Such particular circumstances must include, without limitation, legal, medical, or security reasons, when obtaining consent is made impossible or impracticable, or when it is in the client’s best interests. The most common method of obtaining client consent is via the client’s confirmed authorization on the credit application form, or using the form provided by the Filogix system, as mentioned above. When possible, the Orbis Mortgage Group may also obtain verbal consent during an interview, followed as quickly as possible by written consent (this is not recommended as a credit reporting agency may refuse this type of consent), or by a document such as an email that clearly includes the client’s name in the email address. Any form of written authorization must clearly specify that the client authorizes the use of their information for obtaining financing, and that such information may be used by a third party.

The client may withdraw their consent at any time by sending a written notice to the address below, subject to any legal or contractual restrictions and within a reasonable time. A client’s refusal to provide consent, or subsequent withdrawal of consent, may affect the Orbis Group’s ability to provide mortgage services to that client. A member of the Orbis Mortgage Group will inform the client of the implications of such withdrawal.

To withdraw their consent, the client must communicate in writing with the privacy officer at:

Attention: Mr. Theodore Kyres, President Orbis Mortgage Group 285 Place d’Youville, Suite 9 Montreal, QC H2Y 2A4 Tel. : 514-313-0108

Use and disclosure of personal information

We will use the client's personal information to offer financial services and notices, to administer our database, to add the client to our marketing activities, or for any other use described above in the section “Why does the Orbis Mortgage Group collect personal information.” In certain circumstances, the Orbis Mortgage Group may disclose personal information to a third party. Specifically, personal information may be used, shared, and disclosed to, from, or with, Orbis Group members, witnesses in a contentious proceeding, experts hired on behalf of the client, credit bureaus, and third parties necessary to facilitate the matter for which the client has engaged our services and given their consent. In certain circumstances the Orbis Mortgage Group may disclose personal information:

• When required or permitted by law, for example if a court issues a subpoena;
• When the client has consented to the disclosure of that information;
• When the Orbis Mortgage Group provides mortgage services to a client for whom personal information is required by a third party (for example, by a lender during a real estate mortgage transaction); in this case, the client’s consent will be implied unless the client indicates otherwise.
• When it is necessary to call upon a credit bureau for the processing of a mortgage transaction;
• If the Orbis Mortgage Group hires a third party to provide administrative or support services (such as computer backup services or shredding and archiving of records); this third party is bound by our privacy protection policy.
• To protect the best interests of Orbis;
• To protect public interests or to report criminal activities such as fraud or money laundering. In these situations, authorities will be contacted and personal information may be disclosed.
• If we retain the services of a law firm to act on our behalf, for any reason; or
• If the information is already publicly known.

Limitation of collection and retention of personal information

The Orbis Mortgage Group limits the collection of a client’s personal information to what is necessary for the purposes described in the privacy policy, which may be amended from time to time, or for other purposes identified to the client before collection. In addition, personal information collected may only be used or disclosed for the purposes for which it was collected, except with the client’s consent or otherwise authorized by law.

Accuracy

The Orbis Mortgage Group strives to ensure that the client’s personal information is as accurate, complete, and up-to-date as possible for the purpose for which it is used. Before submitting a transaction to a lender, the agent must validate the information received and ensure its accuracy, in line with best practices. These practices involve confirming the client’s identity and carefully reviewing any documentation such as income, deposits, appraisals, purchase and sale offers, or any other document relevant to each transaction, and before submitting the file to a lender. This step is necessary for the processing of each transaction to prevent any fraudulent activity. Each agent is responsible for ensuring that all information collected is accurate and fully disclosed to each lender to whom they submit their transaction for approval, as stipulated in their Independent Agent agreement.

For agents who wish to attend our training on points to look for during the documentation review during the transaction, the Orbis Mortgage Group holds quarterly fraud prevention sessions. It is also recommended that our agents review frequently asked questions on the AMF site at www.lautorite.qc.ca

For those with questions about standard practices, agents may obtain information from the AMF's contact center or by calling (514) 395-0337 for more information.

Security

The Orbis Mortgage Group strives to maintain a maximum level of security to protect the backup of data against loss, theft, unauthorized access, disclosure, reproduction, as well as the use or modification of the client’s personal information under the Orbis Mortgage Group’s responsibility. The Orbis Mortgage Group uses various methods to protect personal information, including physical security, information technology and electronic security, destruction of information no longer needed, and contractual protections with data subcontractors. Paper copies requested by the AMF are kept at the head office for 12 months, or until they are digitized. All AMF-required prior files are kept at the same address and are available on request from the concerned parties.

Protection

The client list is never transmitted to a third party other than members affiliated with the Orbis Mortgage Group. During hiring, employees and agents must commit to respecting the confidential nature of client information. Only employees and associates who need to consult the files within the scope of their duties have access to this information.

Privacy policy changes

From time to time, the Orbis Mortgage Group reviews and revises its privacy protection practices. The policies, new or modified, will be announced on this page promptly.

The Orbis Mortgage Group website

Our website may contain links to other sites that are not governed by this privacy protection policy. On our website, as on most commercial websites, we may monitor transmission habits, site usage, and related information to optimize our service. We may provide aggregate information to third parties, but these statistics do not include personal information revealing your identity. The Orbis Mortgage Group website, as well as all agent websites, must clearly indicate the address and contact information of the head office, as well as the broker license number, issued by the AMF. All license numbers are also displayed on the Orbis Mortgage Group site and must be clearly displayed on each agent’s website.

The Orbis Mortgage Group requires all its agents who create websites to submit all website content to our privacy and compliance officer before it is published and made accessible to the public. A quarterly review of our agents’ websites ensures ongoing compliance. It is noted in the independent agent contract that each agent must sign when hired by our firm.

Contacting the Orbis Mortgage Group

We recognize that ease and speed of access should not override security requirements. We use different means to communicate with our clients, some of which are more convenient, such as emails. Our emails are sent in accordance with industry standards with 128-bit encryption. However, such encryption does not guarantee privacy or security since encrypted messages may be intercepted and decrypted. If the client prefers not to use emails as a means of communication, they should discuss this with the consultant/broker/agent handling their file to find an alternative solution.

Attention: Theodore Kyres, President Orbis Mortgage Group 285 Place d’Youville, Suite 9 Montreal, QC H2Y 2A4 Phone: (514) 313-0108

Data security and storage

Each agent and broker must take reasonable steps to protect the personal data provided by the client. Each original document will be kept in a secure place not accessible to the public. When a file is complete, all unnecessary documents are immediately returned to the client. If the original documentation comes from the client, it will be submitted to the head office, either in paper or electronic form, before closing the transaction. While the agent must keep a copy of the file, they are required to take all reasonable steps to protect the confidentiality of the documents in their possession, as they are responsible for protecting all confidential and private information entrusted to them.

Note that all files are the property of the Orbis Mortgage Group. While brokers and agents retain data for marketing purposes, the clients belong to the Orbis Mortgage Group.

Any documentation that is no longer needed must be shredded immediately. Any electronic documentation must be password-protected. Laptops containing client files must never be left unattended in a public place.

The head office will take the necessary steps to ensure the security of client file data. Digitized documents must be adequately protected and cataloged. All client files as well as personal files must be kept in a locked cabinet or in a secure electronic format. All computers at our head office are password-protected and data is regularly backed up on our external/mobile hard drive to be stored each night at a secure off-site location. All digitized documents are shredded immediately or stored in a secure locked cabinet until shredded by an external firm. We currently use Iron Mountain services.

Retention of files

Completed mortgage files will be retained for six years after the mortgage maturity date. All documents not related to the mortgage will be retained for six years. Documentation related to canceled or incomplete files will be retained for at least one year, except consent forms, which must remain on file for three years, in case a credit reporting agency requires proof of client consent to obtain a report. All paper copies will be shredded after this period.

COMPLAINTS

Upon receipt of a complaint from a consumer or investor, the complaints officer (or a designated person) will take immediate investigative measures. If the complaint concerns a completed file, the complaints officer will extract the existing documentation from the company’s files. The complaints officer will review the documentation, then forward the complaint to the agent or broker involved to obtain comments. If the complaint concerns an active file, the complaints officer will immediately contact the agent or broker responsible for the file and forward the complaint for their comment, and together they will review the involved file. The complaints officer will respond verbally to all complaints within 48 hours of receipt, and will follow up in writing as soon as possible. If a satisfactory solution cannot be found, the written response should propose that the matter be referred to the AMF. All documentation related to a complaint must be retained in accordance with file handling requirements, and a copy will be kept in the HR agent file, which is archived at the Orbis Mortgage Group head office.

Complaints can be submitted directly via the Orbis website: https://groupeorbis.com/contactez-nous/