Trinidad & Tobago Mortgage Finance Company Limited (“TTMF”), owns and operates the Web site located at the URL www.ttmf-mortgages.com (the Site), and portions of other Web pages and Web content through which you have accessed this privacy policy. By visiting, using and/or submitting information to the Site, you are accepting the practices described in this Privacy Policy and the terms and conditions of TTMF’s Agreement of Terms of Use located at the URL www.ttmf-mortgages.com/ttmf/legal/terms-and-conditions (the “Terms of Use”).

TTMF takes your privacy seriously, and has published this Privacy Policy to explain how TTMF treats all information you may submit to the Site.

Collection of Personally Identifiable Information

Many of the features of the Site are available to you without you providing personally identifiable information. Personally identifiable information generally includes information that could be used to determine your identity, such as your name, address, phone number, e-mail address, and birth date (Personally Identifiable Information). The following are certain situations in which TTMF may collect Personally Identifiable Information from you:

Registration for newsletters and contests

TTMF collects Personally Identifiable Information from you if you register online for one of TTMF’s newsletters and when you enter TTMF’s contests. When you register online with TTMF, TTMF asks for Personally Identifiable Information like your name, address, phone numbers, e-mail address, birth date, gender, occupation, industry, personal interests and other demographic information.

Use of Forums

If you choose to transmit, submit or post information through TTMF’s chat rooms, bulletin boards or other forums (the “Forums”), TTMF will collect that information you provide. TTMF retains this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law and pursuant to TTMF’s Terms of Use.

Form

TTMF may collect Personally Identifiable Information from you if you choose to fill out any forms, profiles, or surveys on the Site.

Correspondence

If you send TTMF personal correspondence, such as emails or letters, or if other users or third parties send TTMF correspondence about your activities or postings on the Site, TTMF may choose to collect such information into a file specific to you.

Use of Personally Identifiable Information

TTMF uses your Personally Identifiable Information as follows:

• to improve TTMF’s marketing and promotional efforts, analyse site usage, improve TTMF’s content and product offerings, and customise TTMF’s content, layout, and services;
• to contact you and deliver information to you that, in some cases, is targeted to your interests, such as targeted banner advertisements, administrative notices, product offerings, and communications relevant to your use of the Site;
• to fulfill your requests for certain products and services;
• for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity, to enforce the Terms of Use, for other internal purposes, and as otherwise described to you at the time of collection; and
• as otherwise set forth in this Privacy Policy.

You expressly agree to TTMF’s use of your Personally Identifiable Information as set forth in this Privacy Policy and the Terms of Use.

Disclosure of Personally Identifiable Information

Unless you are entering one of TTMF’s contests, TTMF will not disclose your Personally Identifiable Information to any external party unless authorised by the user or unless required to do so by law. The following describes some of the ways that your Personally Identifiable Information may be disclosed in the normal scope of business:

Advertisers

TTMF may aggregate Personally Identifiable Information and disclose such information in a non-personally identifiable manner to advertisers and other third parties for their marketing and promotional purposes. For example, TTMF may aggregate Personally Identifiable Information and disclose it to network advertisers in a non-personally identifiable manner as set forth in the section entitled “Network Advertisers,” set forth below. TTMF does not disclose your information in a personally identifiable manner to such third party advertisers without your consent.

External Service Providers

There are a number of separate services offered by third parties, including, without limitation, TTMF’s affiliates, that TTMF refers to as external service providers that may be complementary to your use of the Site (e.g. realtors, mortgage brokers, lenders, financial institutions, credit card issuers, information aggregators). If you choose to use these separate services, disclose information to the external service providers, and/or grant them permission to collect information about you, then their use of your information is governed by their privacy policy. With your consent, TTMF may provide some of your Personally Identifiable Information to the external service provider offering such services, for your convenience. To prevent TTMF’s disclosure of your Personally Identifiable Information to an external service provider, you can decline such consent or simply not use their services. You should evaluate the practices of external services providers before deciding to use their services.

Internal Service Providers

TTMF may use third parties that TTMF refers to as internal service providers to facilitate or outsource one or more aspects of TTMF’s business, product and service operations that TTMF provides to you (e.g., technology, Forums, newsletters/alerts, analytical tools, advertising campaign management) and therefore TTMF may, with your consent, provide some of your Personally Identifiable Information directly to these internal service providers. These internal service providers are subject to confidentiality agreements with TTMF or other legal restrictions that prohibit their use of the information TTMF provides them for any other purpose except to facilitate the specific outsourced TTMF related operation, unless you have explicitly agreed or given your prior permission to them for additional uses. In some instances, the internal service provider may collect information directly from you. In these cases, you will be notified of the involvement of the internal service provider, and all additional information you provide them and their additional uses will be strictly up to you. If you provide additional information to an internal service provider directly, then their use of your Personally Identifiable Information is governed by their applicable privacy policy.

Notwithstanding the foregoing, TTMF reserves the right (and you authorise TTMF) to share or disclose your Personally Identifiable Information when TTMF determines, in its sole discretion, that the disclosure of your Personally Identifiable Information is necessary to identify, contact, or bring legal action against you if:

• you are or may be violating TTMF’s Terms of Use;
• you are interfering with another’s rights or property, including, without limitation, TTMF’s rights or property;
• you are violating any applicable law, rule or regulation;
• necessary or required by any applicable law, rule or regulation; and/or
• requested by authorities in the event of any act of terrorism or instance of local, regional or national emergency.

Personally Identifiable Information and other personal information collected from you may with your consent also be transferred to a third party as a result of a sale, acquisition, merger, reorganisation, other transfer or bankruptcy (a “Transfer”) involving TTMF and/or its affiliates. TTMF specifically reserves the right to transfer Personally Identifiable Information collected from the Site, and any of its databases, together with any Personally Identifiable Information contained therein, to a third party in connection with a Transfer, and nothing in this Privacy Policy is intended to interfere with the ability of TTMF to transfer all or part of its business and/or assets (including the Site) to an affiliate or independent third party at any time, for any purpose, without any limitation whatsoever.

In addition, TTMF shall not be liable for any disclosure of your Personally Identifiable Information where any third party has unlawfully intercepted or accessed transmissions or private communications.

NOTE: If you are submitting Personally Identifiable Information pursuant to sweepstakes entry, TTMF will not share, loan, rent and/or sell the Personally Identifiable Information that you submit with its affiliates and other third parties. Please refer to the Official Rules and Privacy Policy for each individual sweepstakes for the specific guidelines regarding information sharing and disclosure.

Network Advertising

TTMF may use third-party advertising companies for marketing, advertising and promotional purposes, as well as to serve advertisements to you. Using third-party advertising companies helps us and third-party advertisers better determine which advertisements or content to serve to you. For example, the third-party advertisers may use information regarding your visits to the Site and other Web sites in order to provide advertisements about goods and services, that third party advertisers believe will be of interest to you.

The types of information that may be collected by third-party advertising companies include the following:

• the type of Internet browser you use;
• the type of computer operating system you use;
• the domain name of a Web site you visit, as well as information related to Web sites and Web pages you are viewing when an advertisement is requested;
• whether or not you visit specific pages of the Site or other Web sites;
• the location of your Internet service provider’s point of presence;
• the date and time of a visit to a Web site;
• search keywords passed from another server;
• the number of times you have clicked on an advertisement; and
• other interactions between you and a Web site.

If you would like more information about this practice and to know your choices about not having this information used by these companies, email us at
info@ttmf-mortgages.com.

Opt-Out and Changes to PERSONALLY IDENTIFIABLE INFORMATION and Use Preferences

You may at any time request a copy of TTMF’s record of your Personally Identifiable Information , change your Personally Identifiable Information or use preferences, or opt-out of TTMF’s use of your Personally Identifiable Information by contacting TTMF at info@ttmf-mortgages.co.

Newsletters and CAN-SPAM Compliance

The Site sends only verified, double-opt-in e-mail newsletters, specifically requested by TTMF subscribers. Subscriptions to the Site’s newsletters are verified by sending an e-mail confirmation to your e-mail address, which requires a positive response before an e-mail address is added to TTMF’s list.

Cookie technology

“Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by your Web browser on your computer’s hard drive. TTMF, its external service providers, internal service providers, and third-party advertising companies, may set and access cookies on your computer to track and store preferential information about you. TTMF, and its external service providers, internal service providers, and third-party advertising companies gather anonymous information about you through cookie technology on an aggregate level only. For example, a third-party advertising company may assign a cookie (and a Web beacon, described below) to you, to limit the amount of times you see a particular advertisement or to help better determine which advertisements to serve to you. Please note that most Internet browsers will allow you to stop cookies from being stored on your computer and to delete cookies stored on your computer.

Web beacons

“Web beacons”, also called single-pixels (1×1) or clear GIFs, are electronic images that allow a Web site to access cookies and help track marketing campaigns and general usage patterns of visitors to those Web sites. Web beacons can recognise certain types of information, such as cookie numbers, time and date of a page view and a description of the page where the Web beacon is placed. No Personally Identifiable Information about you is shared with third parties through the use of Web beacons.

• Internal use of Web beacons
• TTMF may use Web beacons internally to count users and recognise users through cookies. Access to cookies helps TTMF personalise your experience when you visit the Site.
• E-mail
• TTMF may include Web beacons in HTML-formatted e-mail messages that TTMF or its affiliates or agents send. Including Web beacons in e-mail messages helps TTMF determine your interest in and the effectiveness of such e-mails.
• External use of Web beacons:
  TTMF may also use Web beacons externally. For example, TTMF may report aggregate information about the Site users, such as demographic and usage information, to its partners and other third parties. TTMF may also include other company’s Web beacons within the Site.

Security

Personally Identifiable Information you submit to TTMF is password-protected for your privacy and security. In certain areas TTMF uses industry-standard SSL-encryption to protect data transmissions. In the unlikely event that an unauthorised third party compromises TTMF security measures, TTMF will not be responsible for any damages directly or indirectly caused by an unauthorised third party’s ability to view, use or disseminate such information.

Links to Other Web sites

The Site may include links to other third party Web sites. Such links are not an endorsement by TTMF of those Web sites and/or the products or services offered there. Third party Web sites may have different privacy policies and TTMF is not responsible for the privacy practices of those third party Web sites. If you click on a link to a third party Web site, TTMF encourages you to check the privacy policy of that Web site, as it may differ substantially from that of this Privacy Policy.

Changes to this Privacy Policy

TTMF reserves the right to update, amend and/or change this Privacy Policy at any time in its sole discretion and without notice. Updates to this Privacy Policy will be posted to this web page. Any information TTMF collects from you online is subject only to TTMF’s most current Privacy Policy. You are encouraged to revisit this Privacy Policy from time to time in order to review any changes that have been made. TTMF’s last update was June 1, 2011. Your continued access and use of the Site following the posting of any such changes shall automatically be deemed your acceptance of the same.

Questions or Concerns

If you have questions, comments, concerns or feedback regarding this Privacy Policy, send an e-mail to info@ttmf-mortgages.com.

Miscellaneous

If any portion of this Privacy Policy is deemed unlawful, void or unenforceable by any arbitrator, this Privacy Policy as a whole shall not be deemed unlawful, void or unenforceable, but only that portion of this Privacy Policy that is unlawful, void or unenforceable shall be stricken from this Privacy Policy.

The headings contained in this Privacy Policy are for convenience of reference only, are not to be considered a part of this Privacy Policy, and shall not limit or otherwise affect in any way the meaning or interpretation of this Privacy Policy.

All covenants, agreements, representations and warranties made in this Privacy Policy, as may be amended by TTMF from time to time, shall survive your acceptance of this Privacy Policy.

This Privacy Policy and the Terms of Use available at the URL www.ttmf-mortgages.com/ttmf/legal/terms-and-conditions represent the entire understanding and agreement between you and TTMF regarding the subject matter of the same, and supersede all other previous agreements, understandings and/or representations regarding the same.