Complaints management policy

Preamble

Mortgage Fox provides a technology solution intended in particular for mortgage brokerage professionals. This policy applies to complaints related to Mortgage Fox's technology activities: platform, features, support, billing, security, personal information protection, automation and artificial intelligence.

This policy is not the regulatory policy of a mortgage brokerage firm and does not, by virtue of providing its technology alone, make Mortgage Fox a mortgage firm, lender, insurer, legal or tax advisor, or credit decision-maker. When a complaint primarily concerns the professional acts or obligations of a user, firm, lender or other third party, Mortgage Fox may direct the complainant to the responsible entity while still handling any portion of the complaint that relates to its own services or obligations.

1. Purpose and scope

• users, administrators, brokers, firms and client organizations;
• persons whose information is processed on the platform;
• website visitors and persons who communicate with Mortgage Fox;
• complaints relating to operation, availability, billing, support, security, privacy, automated output or an AI feature.

2. Definitions

Complaint: expression of a grievance against Mortgage Fox, its services, systems, personnel or a supplier acting on its behalf, with or without actual or potential harm or a request for corrective action.

Support request: question, request for assistance, bug report or request for information normally resolved in the course of regular operations and that does not, in substance, constitute a formal grievance.

Privacy complaint: complaint concerning the collection, use, disclosure, retention, destruction, security or any other processing of personal information.

Privacy incident: unauthorized access, use or disclosure of personal information under applicable law, loss of information or other breach of its protection.

AI-related complaint: complaint concerning an extraction, summary, classification, recommendation, generated output, alleged bias, automated decision or other algorithmic processing.

3. Processing principles

• free process;
• fair, impartial and proportionate handling;
• confidentiality and access limited to persons who need to be involved;
• no retaliation for a good-faith complaint;
• maintenance of a reasonable audit trail;
• priority for situations involving security, privacy, data integrity, multiple users or significant risk of harm;
• separation, to the extent reasonably possible, between the person named in a complaint and the person who decides the outcome.

4. Responsible person

The person responsible for implementing this policy is Mr. Jean-François Choquette. He coordinates receipt, the register, investigation, communications and corrective measures. He may engage technical, legal, security, privacy or specialized supplier resources when necessary.

Responsible person
Mr. Jean-François Choquette

Address 1
1060 Michèle-Bohec Blvd., Suite 101, Blainville, Quebec J7C 5E2

Address 2
893 Taniata Ave., Lévis, Quebec G6Z 2E3

Phone
418-204-7738

Email
info@consortiumhypothecaire.com

5. What may constitute a complaint

• significant, repeated or unresolved malfunction after reasonable support;
• alleged error in a calculation, extraction, recommendation or content produced by the platform;
• AI output alleged to be inaccurate, inconsistent, biased, discriminatory, misleading or inappropriate;
• alleged data loss or alteration, significant unavailability or unauthorized access;
• billing, subscription, account administration or account closure;
• collection, use, disclosure, retention, destruction or anonymization of personal information;
• security weakness or incident;
• conduct of a staff member or supplier acting for Mortgage Fox.

A suggestion, question, training request or ordinary support ticket is not a complaint on its own. Classification depends on the substance of the request, not the label used by the complainant.

6. Filing a complaint

A complaint may be made verbally or in writing. Mortgage Fox may require a verbal complaint to be confirmed in writing or may record the details itself and ask the complainant to validate the summary. A complaint relating to the exercise of a right of access or rectification is subject to the written requirements provided by applicable law.

To facilitate analysis, the complaint should specify, where possible:

• complainant's name, contact information and organization;
• account, file, feature or interaction concerned;
• date and description of the facts;
• alleged actual or potential harm;
• desired corrective action;
• screenshot, transaction identifier or useful document, avoiding transmission of more personal information than necessary.

Responsible person
Mr. Jean-François Choquette

Address 1
1060 Michèle-Bohec Blvd., Suite 101, Blainville, Quebec J7C 5E2

Address 2
893 Taniata Ave., Lévis, Quebec G6Z 2E3

Phone
418-204-7738

Email
info@consortiumhypothecaire.com

7. Opening a file and acknowledgement of receipt

As soon as a request is identified as a complaint, a file is opened and the complaint is entered in the register. Mortgage Fox acknowledges receipt without undue delay and aims, as an internal service target, to do so no later than five (5) business days.

The acknowledgement may include a summary of the complaint, the person handling it, a request for additional information, next steps, a non-guaranteed time estimate and a reminder not to transmit unnecessary sensitive information.

8. Triage, risk level and escalation

Each complaint is triaged according to its nature, scope and risk level. A situation that may constitute a privacy incident, cybersecurity breach, fraud or systemic problem affecting multiple users is immediately escalated to the appropriate resources.

• possible interim measures: suspension of access, session revocation, temporary limitation of a feature, isolation of a process or preservation of logs;
• preservation of evidence necessary for the investigation;
• notice to the privacy officer when personal information is involved;
• notice to insurers, advisors or authorities when required or reasonably appropriate.

An interim measure is taken for prevention, security or preservation of evidence and does not constitute an admission of liability.

9. Investigation

The investigation is limited to what is reasonably necessary to understand the facts, identify the cause and determine appropriate measures. The responsible person may consult, as applicable, activity logs, version histories, settings, documents, screenshots, produced results, audit trails, relevant suppliers and authorized staff members.

The complainant cooperates reasonably with the investigation. If essential information is not provided after a reasonable request, Mortgage Fox may close the file based on available information, without prejudice to the complainant's legal rights.

10. Artificial intelligence complaints

When a complaint concerns an AI feature or automated processing, Mortgage Fox may examine in particular:

• input data and its accuracy;
• the version, configuration or supplier of the feature;
• rules, instructions, parameters or criteria applied;
• the output produced and human or automated validation mechanisms;
• the existence of a hallucination, inconsistency, manifest bias or output contrary to intended use;
• the ability to reproduce the problem and measures to correct, limit or prevent it;
• whether a decision was based solely on automated processing and, if so, whether information and review rights were respected.

The fact that an AI output is inaccurate does not, on its own, establish fault. The analysis takes into account the probabilistic nature of the technology, intended use, input data, applicable warnings and the professional user's expected validation role.

11. Privacy complaints and incidents

A complaint relating to personal information protection is forwarded to the privacy officer. If the facts may constitute a privacy incident, the incident response process is triggered without waiting for the complaint to be concluded.

Access or rectification requests are handled according to applicable legal deadlines; in Quebec, the responsible person must respond in writing diligently and no later than thirty (30) days after receipt of a valid written request.

12. Administrative processing timelines

Mortgage Fox aims to communicate a final response within thirty (30) days of receiving a sufficiently complete complaint. A complex file, security investigation, in-depth technical analysis, supplier involvement or obtaining additional information may justify a longer timeline.

If processing cannot reasonably be completed within sixty (60) days, Mortgage Fox aims to inform the complainant of the status of the file and, where possible, of a new estimated timeline. These timelines are internal targets and do not replace any mandatory deadline provided by law.

13. Final response and corrective measures

At the end of the review, Mortgage Fox communicates a written, reasoned response adapted to the circumstances. It may summarize the facts retained, verifications performed, outcome and corrective measures taken, subject to confidential information, trade secrets, third-party information or security elements that cannot be disclosed.

• correction of data, a parameter, documentation or a feature;
• resumption of processing or human validation;
• improvement of the interface, training, controls or instructions;
• commercial or billing adjustment where justified;
• security or privacy measures;
• limitation, suspension, modification or withdrawal of a feature;
• escalation to a supplier, insurer, advisor or competent authority.

14. Internal review

A complainant who believes that a significant error or new fact was not considered may request a review by precisely identifying the element at issue. Where possible, the review is assigned to a person who did not make the initial decision.

15. Confidentiality, conflicts and no retaliation

Information related to a complaint is accessible only to persons who need to be involved to handle it, ensure security, comply with a legal obligation or defend Mortgage Fox's rights. Any person with a real or apparent conflict of interest withdraws from handling to the extent reasonably possible.

Mortgage Fox prohibits retaliation against a person who files a good-faith complaint or cooperates with an investigation. This rule does not prevent Mortgage Fox from taking appropriate measures in cases of fraud, abuse, threat, harassment or use contrary to applicable terms.

16. Register and retention

The complaints register contains at minimum the date of receipt, category, summary, risk level, main steps taken, outcome, corrective measures and closing date. Files are retained according to Mortgage Fox's retention schedule and, unless a different legal or operational reason applies, for at least five (5) years after closure.

When a complaint includes a privacy incident, the incident register required by law is maintained separately or by cross-reference and is retained for the minimum regulatory period of five (5) years following awareness of the incident.

17. External remedies

This policy does not prevent any complainant from exercising a remedy provided by law. A personal information protection matter may notably be brought before the Commission d'accès à l'information du Québec when Quebec law applies. When PIPEDA applies, the Office of the Privacy Commissioner of Canada may also have jurisdiction.

A complaint concerning the professional acts of a broker or firm must be addressed to the person or organization concerned and, where relevant, to the competent regulatory body. Mortgage Fox does not replace these mechanisms.

18. Relationship with contracts and no admission

This policy describes a complaints management process. It does not modify applicable terms of use, service agreements, service levels, professional obligations or liability limits, except where mandatory law provides otherwise. Investigating, communicating, correcting a problem or offering a commercial measure does not constitute an acknowledgment of fault, liability or harm.

19. Review and effective date

This policy takes effect on August 7, 2026. It is reviewed at least annually and when a significant change to the platform, use of AI, data processing practices, security or legal framework warrants it.

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Annex A – Minimal complaint form

Complainant's name
Contact information
Organization / account
Date of facts
Complaint category
Description of facts
Actual or potential harm
Desired corrective action
Documents / useful identifiers

Instruction: attach only the information necessary to process the complaint. Avoid documents containing irrelevant sensitive data.

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Main legal references

Text	Sections / elements	Scope in the policy
Act respecting the protection of personal information in the private sector (Quebec)	3.2 to 3.8, 12.1, 30 to 36	Privacy complaint process, incidents, access/rectification rights and automated processing.
Regulation respecting confidentiality incidents	3 to 8	Notice and register when a complaint reveals a privacy incident.
Civil Code of Quebec	35 to 40	Rights relating to privacy and information held about a person.
PIPEDA, where applicable	Part 1	Federal remedies and obligations in certain Canadian activities.