Privacy Policy

Our Commitment To You

Deeded (and its affiliated companies, individuals and organizations) (the “Company”, “we”, “us”, “our”), the privacy of its users, consumers, clients, Legal Service Providers, distributors, retailers, suppliers and other individuals (“you”, “your”) is a top priority. Your privacy is at the core of the way we design and build the services and products we provide to you. We appreciate that you put your trust in us when you provide us with your personal information and we do not take this lightly.

We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We strive to be transparent in the way we process your data. We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your personal information.

Privacy Policy

This Privacy Policy (the “Privacy Policy”) sets out the privacy policies and practices for the Company with respect to how the Company collects your personal information. It also describes how the Company uses, maintains, retains, transfers and discloses your personal information. This Privacy Policy applies to information collected from you by the Company via https://deeded.ca/ and our mobile application (collectively, the “Platform”) and other places where, or means by which, we may collect personal information. This Privacy Policy also sets out how you can access certain information that the Company may collect about you and explains the choices you have regarding any collection, use, maintenance, retention, transfer and disclosure of such information, and how you may access or correct that information. In this Privacy Policy, “personal information” means any information about an identifiable individual or information that allows an individual to be identified, as defined from time to time in applicable privacy legislation. Personal information does not include business contact information such as your name, title or position, business address, telephone number, facsimile number or e-mail address.

Definitions

In Deeded’s Terms of Use and Privacy Policy, the term “User” refers to the person(s) seeking to close or settle a residential real property or mortgage transaction. The term “Legal Service Provider” refers to third-party real estate lawyers or real estate law firms who operate independently of Deeded; the term “Business Partners” refers to parties such as lenders, real estate agents, mortgage agents, and other parties who may be leveraging the Platform; and the term “Transaction” (when capitalized) means a real property or mortgage closing/settlement transaction created and managed in the Platform by the User, Legal Service Provider or one or more Business Partners in order to facilitate communications, access, and use the Services.

For greater clarity, in this Privacy Policy, the term “Services“, when capitalized, refers to those offered and provided by Deeded, that is, the Platform and its features and functionalities and the professional, assistance and support services provided by Deeded itself, and does not refer to any services provided by Legal Service Providers or Business Partners, who operate independently of Deeded.

Your Consent

BY SUBMITTING PERSONAL INFORMATION TO US, YOU AGREE THAT WE MAY COLLECT, USE, MAINTAIN, RETAIN, TRANSFER AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED

OR REQUIRED BY LAW. Subject to legal and contractual requirements, you may refuse or withdraw your consent at any time by contacting the Company’s Privacy Officer at privacy@deeded.ca. If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you, or continue to provide you, with certain services, products or information. You are responsible for ensuring the accuracy of the personal information that you submit to us. Inaccurate information will affect your experience when using the Platform and our ability to contact you as described in this Privacy Policy.

Certain parts of our Platform that are made available to Users who have formally engaged a Legal Service Provider may be subject to additional terms, including those provided in the Legal Service Provider’s engagement agreement, as well as additional privacy and data security provisions. In such cases, both this Privacy Policy and the additional terms will apply.

For greater clarity, nothing in this Privacy Policy shall be interpreted as overriding or limiting a User’s rights to or expectation of confidentiality and solicitor-client privilege as concerns communications between the User and their Legal Service Provider for the purpose of obtaining legal advice. To the extent this Privacy Policy or any portion thereof conflicts with a User’s rights to confidentiality from their Legal Service Provider, the confidentiality and privilege applicable to the solicitor-client relationship shall prevail.

Amendments of This Privacy Policy

We may change, modify, add or remove portions of this Privacy Policy at any time and from time to time, without prior notice to you. We will treat your continued use of the Platform following such change, modification, addition or removal as your acceptance of such revisions. The Policy will be posted on the Platform and will apply to any personal information collected on or after the date posted.

Collection of Your Personal Information

We are the controller and the responsible party for your personal information. We may collect personal information in connection with your use of the Platform or with your use or purchase of the Company’s products and services, which may include personal information provided in connection with your use of the Platform.

When you use our Platform, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our Platform. The personal information that we may collect may include:

• Information you provide to us when you are:
• Registering for an account, you provide us with information that includes but not limited to your name, e-mail address, your legal needs and copies (or photos) of your government issued ID. Registering for an account may require additional information. By choosing to provide this information, you consent to our processing of that information;

• Participating in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials;
• Registering or filling in forms on the Platform;

• Requesting for us to communicate with or otherwise process information of other people and in such instances, we collect the information about others that you give us in order to complete your request. If you provide us with personal information of another individual, you represent to us that you have that individual’s consent to allow us to collect, use, maintain, retain, transfer and disclose that personal information in accordance with this Privacy Policy;

• Requesting information or assistance from the Company. This includes information you may provide when you request additional information about the Company’s products and services or sign up to receive the Company’s e-mail newsletters or coupons. The Company may also keep a copy of any communications or correspondence you may send to it, including any e-mail communications; and

• Using other features, including interactive functions of the Platform that may be offered from time to time, and may require such information in order to utilize the feature;

• Information others provide to us about you. We will apply this Privacy Policy to any personal information received from third parties, unless we have disclosed otherwise. In addition to the information you provide to us directly, we may receive information about you from other parties, for instance:

• Our Business Partners may provide information about you as they use our products and services. We may also collect information about you from other users if they contact us about you or leave a review on our Platform;
• Instead of registering for an account with our Platform directly, you may log in to the Platform using sign-in services such as Twitter, Facebook and Google. Such sign-in features eliminate the need for you to create a username and password for our Platform and allow you to authenticate your account using your existing social media identity and pre-verified user account. These services will also provide you with the option to share certain personal information with us such as your name and e-mail address. Prior to using any such sign-in services, please review the privacy
  

policies of these social media providers as they may have different policies and practices than us. We do not assume any responsibility for the privacy practices, policies or actions of the operators of these social media platforms; and

• We may receive personal information about you from our Legal Service Providers, including through the use of our Platform, consistent with the consent you have given to your Legal Service Provider and as governed by your engagement agreement with your Legal Service Provider and their applicable professional conduct rules.

• We may supplement the information we collect about you through the Platform with records received from third parties in order to enhance our ability to serve you, to verify your identity, to tailor our content to you, and to offer you information that we believe may be of interest to you.

• Information collected when you use the Platform. When you use our Platform, we collect information about which features you’ve used, how you’ve used them and the devices you used to access our Platform.For instance, we collect information:
• About your activity on our Platform (for example, date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on, etc.) and how you interact with other users (for example, users you connect and interact with, time and date of your exchanges, number of messages you send and receive, etc.) and your relationship with such users;
• About the device(s) you use to access our Platform including:

• hardware and software information such as manufacturer, model, IP address, device identification and type, operating system and identifiers associated with cookies or other technologies that may uniquely identify your device or browser (such as, IMEI/UDID and MAC address);

• information on your wireless and mobile network connection such as, your Internet Service Provider and signal strength and information on device sensors (such as accelerometers, gyroscopes and compasses);

• From the device(s) you use to access our Platform including your:

• Geographic location, IP address; and
• device-specific and application settings and characteristics, application crashes, advertising IDs (such as Google LLC’s AAID and Apple Inc.’s IDFA), browser type, version and language, time zones, etc.; and

• Other information with your consent such as:
  

• your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, magnetic field sensors, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the Platform if the permission you gave us expressly permits such collection;
• your photos, images and videos (for instance, if you want to publish a profile photo, or recording your video for security and compliance purposes during a virtual document signing session); and
• any other personal information that you choose to include in your account; and
• any other information you have submitted; and
• any other communications to the Company.

We may collect personal information even when you are not using the Platform. We may combine personal and non-personal information about you collected by us or by our affiliates, retailers, distributors and other third parties with whom we have a relationship, and we may combine this information with information from external sources.

In obtaining your consent to collect, use, maintain, retain, transfer and disclose your personal information we will use reasonable efforts to inform you of the purpose for which personal information will be collected, used, maintained, retained, transferred or disclosed. The form of consent may vary depending on the circumstances and type of information disclosed. We will take into account the sensitivity of the personal information and your reasonable expectations when determining the appropriate form of consent.

Online Communications

You may voluntarily submit personal information to us for purposes such as asking a question, obtaining information, reviewing or downloading a publication, registering for an account, purchasing a product or service, reviewing a product or service provided by the Company or by another user of the Platform, receiving a review of your product or service from another user of the Platform, subscribing to a newsletter or a mail or e-mail list and participating in contests and surveys. If you are a registered user on the Platform, we may combine and store personal information about your use of the Platform and information you have provided to us with certain other online and offline information we may have collected.

E-mail Communications

We may send you marketing or promotional e-mail communications. In this process, we may collect certain information such as the date and time you first opened our e-mail communications, the number of times you open our e-mail communications, the number of instances you click through our articles and your total click-through activity on the contents of our e-mail communications. We may also combine and store any such information to manage and improve our e-mail communications. If you no longer wish to receive any future marketing or promotional material from us, our promotional e-mail communications will include instructions on how to unsubscribe and inform us of your preferences.

Cookies

We aim to provide a secure Platform and to improve our Platform for you, including by remembering your preferences, recognizing you when you visit our Platform and personalizing and tailoring ads to your interests. To accomplish these purposes, we may use a browser feature called a “cookie” to collect information when you access the Platform. A cookie is a small text file containing a unique identification number that identifies your browser, but not necessarily you, to our computers each time you visit the Platform. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your device, such as user settings, browsing history and activities conducted while using our Platform. We also may link information from cookies with other personal information we hold about you. In addition to the purposes described in our Privacy Policy, we may use such personal information and share it with third parties with whom we have a commercial relationship to measure the use of the Platform, to improve the functionality and content of the Platform and to simplify your usage of the Platform.

We also use similar technologies for example, web beacons, Facebook Pixel and cookies that other third-party ad-networks use, that enable us to recognise when someone has visited our Platform or opened an e-mail that we have sent them. For simplicity, we also refer to these technologies as “cookies” in this Privacy Policy.

There are different types of cookies, including:

• First-party cookies, which are cookies placed on your device directly by us;

• Third-party cookies, which are cookies placed on your device by our affiliates and Legal Service Providers;

• Session cookies, which only last until you close your browser or exit the Platform. We use session cookies for various reasons, including to learn more about your use of our Platform during one single session and to help you to use our Platform more efficiently; and

• Persistent cookies, which have a longer lifespan and are not automatically deleted when you close your browser or exit the Platform. These types of cookies are primarily used to help you quickly sign-in to our Platform again and for analytical purposes.

When you use our Platform, some or all of the following types of cookies may be set on your device:

• Essential website cookies: we use such cookies to provide you with the products and services available on our Platform and to use the features of our Platform;
• Analytics cookies: we use such cookies to understand how you use our Platform and how effective our marketing campaigns are and help us customize and improve our Platform for you;

• Advertising cookies: we use such cookies to make our advertising messages more relevant to you, for instance by preventing the same ad from continuously
  

reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on your interests, and measuring the number of ads displayed and their performance; and

• Social networking cookies: we use such cookies to enable you to share pages and content that you find interesting on our Platform through third-party social networking platforms and other websites and applications. We may also use these types of cookies for advertising purposes. Depending on your social media account settings, we automatically receive information from the social media platform. To learn more about social media cookies, please refer to your social media platform’s cookie policy and privacy policy.

Unless you specifically inform us (for instance, by sending us correspondence from the Platform), we will not know who you are. You can reset your browser either to notify you when you receive a cookie or refuse to accept cookies. If you refuse to accept cookies, you may not be able to use some of the features available on the Platform.

We would like to provide you with some information about controlling your cookie settings. Some web browsers allow you to control or reject cookies or to alert you when a cookie is placed on your computer. Please review the specific steps involved for such settings in your particular browser help menu as each browser uses different procedures. You also may be able to reset device identifiers by activating the appropriate setting on your device. The procedure for managing device identifiers is slightly different for each device so please review the specific steps in the help or settings menu of your particular device. With respect to interest-based advertising tools, you may opt out of seeing online interest-based advertising from participating companies by using the following applications: (a) the Digital Advertising Alliance; (b) the Interactive Digital Advertising Alliance; or (c) Appchoices. Please note that opting out does not mean you will not see any advertisements; it only means that you won’t see personalized advertisements from the companies that participate in the opt-out programs. Lastly, if you delete cookies on your device after you opted out, you will need to opt-out again.

Third Party Websites

We may also include links to other websites on the Platform or in our e-mail communications. These third-party websites may collect your personal information and they may have different privacy policies and practices than us. We do not assume any responsibility for the privacy practices, policies or actions of the third parties operating these third-party websites. We strongly encourage you to read the privacy policies of these websites to enable you to make an informed decision whether to provide your personal information to these websites’ operators.

Third-Party Analytics

To evaluate the usage of the Platform, we use automated devices and applications provided by third parties, such as Google Analytics. We use these tools to help us improve our products and services, our performance and user experiences. These entities may: (a) use cookies and other tracking technologies which collect information to perform their services; and (b) collect personal information directly through the use of cookies and other tracking technologies. Please go to these

third-party websites to learn more about their privacy policies. If you wish to opt out of Google Analytics data collection, please use the Google Analytics Opt-Out Browser Add-On.

IP Addresses

An IP address is a device’s numeric address, by which it can be located within a network. We may record your IP address when you visit the Platform. We may use your IP address to: (a) help diagnose problems with the Company’s server; (b) administer the Platform; (c) identify you when we believe it is necessary to enforce compliance with this Privacy Policy or the Terms of Use; or

1. protect the Platform and our systems, information, employees, Legal Service Providers, Business Partners, affiliates, users, customers, distributors, retailers and others.

Protection of Your Personal Information

To: (a) prevent unauthorized access to, or disclosure of, personal information; (b) maintain data accuracy; and (c) facilitate the appropriate use of your personal information, we use physical, technological and administrative procedures to protect your personal information that we collect from loss, unauthorized access, modification, unauthorized disclosure or other misuse. Nevertheless, internet or wireless transmissions are never completely private or secure. You understand that any messages, content or information you send or submit through the Platform may be read or intercepted by others. If you have any questions about the security of your personal information collected by us, please contact the Company’s Privacy Officer at privacy@deeded.ca.

Use of Your Personal Information

Once we collect your personal information, we may use such personal information internally, separately or in combination with any pre-existing information for the following purposes:

• To provide our products and services to you, including:
• To determine whether a Legal Service Provider may be able to provide legal services to a User over our Platform;
• To administer your account;
• To process and fulfill your services, including to send you e-mails to confirm your service status, and other related e-mails;
• To develop, enhance, market, sell or otherwise provide information, products or services;
• To contact you and to respond to any communications that you may have had with us;
• To conduct or administer contests, sweepstakes or other promotions in which you have participated; and
• To distribute our newsletters and other informational e-mail communications and other material to individuals on our mail and e-mail lists;
• To connect you with other users of the Platform, including:
• To show users’ accounts to one another; an
• To enable collaboration between us, our Legal Service Providers and Business Partners on matters pertaining to your Transaction.
• To ensure consistent experience with our Platform across all of your devices, including:
• To troubleshoot problems with the Platform;
• To customize your experience or homepage on the Platform;
• To obtain your feedback on the Platform, our products and services; and
• To establish and conduct commercial relationships, including to process transactions and to conduct or administer other transactions that you may engage in with us;
• To improve our products and services and to develop new products and services, including:
• To conduct surveys, research, evaluations and measurement activities, and convey this information to Business Partners and Legal Service Providers; and
• To help us learn more about your preferences.
• To prevent, detect and fight fraud or other illegal or unauthorized activities, including:
• To detect, and to protect the Company and other third parties against, error, negligence, breach of contract, fraud, theft and other illegal activity; and
• To audit compliance with our policies and contractual obligations;
• To ensure legal compliance, including:
• To enforce our Terms of Use and this Privacy Policy;
• As permitted by, and to comply with, any legal or regulatory requirements or provisions; and
• To use, maintain, retain, transfer and disclose your personal information if the Company is required to do so by law; and
• For our business purposes, including:
• To engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving the Company;
• To market, sell or otherwise provide products and services of third parties with whom we have a commercial relationship;
• To develop and manage our business and operations; and (iv)For any other purpose to which you consent.
• To process your information as described above, we rely on the following legal bases:
• The primary reason we process your personal information is to perform the Services we have agreed to provide to you;
• We may use your personal information where we have legitimate interests to do so, for example to improve our products and services by analyzing users’ behavior on our Platform and for administrative, fraud detection and other legal purposes; and
• We may occasionally ask for your consent to use your personal information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

Disclosure of Your Personal Information

Except as provided for in this Privacy Policy, we will not sell, rent, lease, commercially exploit or otherwise disclose your personal information or data to third parties unless: (a) we are required to do so by law or to cooperate with legal investigations; (b) it is required to protect the legal interests of the Company, including for credit checking and collection purposes or in connection with a potential financing, merger or acquisition; or (c) you provide consent to such disclosure.

Occasionally, we may disclose your personal information to:

• A person who, in our reasonable judgment, is providing or seeking the information as your agent;
• Our personnel or contractors;
• Government authorities such as land registries; regulatory agencies; tax authorities; insurers; benefits providers; banks; lenders; consultants or agents, where reasonably necessary to perform the Services or where required by law; and
• Any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.

In certain situations, we may use, maintain, retain, transfer or disclose your personal information without your knowledge or consent (as permitted or required by law). Such situations may be:

• Where your personal information is publicly available;
  
• Where collection or use of the personal information is unmistakably in your interests and consent cannot be obtained in a timely manner;

• To investigate a breach of an agreement or a contravention of law;

• In the event of a corporate change in control of the Company resulting from, for example, a merger, a reorganization, a sale of assets or bankruptcy;

• To comply with a subpoena, warrant, court order or as required or otherwise permitted by law; and

• When information is being collected for the detection and prevention of fraud or for law enforcement.

To help facilitate interactions between Users and third-party Legal Service Providers, Deeded may share certain information, including personal information, with Legal Service Providers over our Platform to enable you to obtain legal services from Legal Service Providers using our Platform and to ensure adequate performance of the contract between the Company and its Users (as such term is defined in our Terms of Use). This includes the following disclosure of information:

• When a User requests a quote for services from our network of third-party Legal Service Providers, retains a Legal Service Provider, or requests a quote from a specific Legal Service Provider profile, Deeded shares certain information about you with the Legal Service Provider (and the Legal Service Provider’s law firm, if applicable), including your full name and name of your business, if applicable; and certain information about your need for services shared in our survey, including type of Transaction, address of your property, and other information you agree to provide in your request. When you retain a Legal Services Provider, we may disclose additional information you have provided to Deeded to your Legal Service Provider to assist with coordinating the services, such as your phone number or email, copies of agreements and relevant documents you have uploaded, your identification and answers to onboarding questions, and your location (including IP address);

• When a Legal Service Provider has been retained by a User, certain information about the Legal Service Provider is shared with the User (and the User’s organization, if applicable) to coordinate the services requested, such as the Legal Service Provider’s profile, full name, address, email, phone number, scope of work, billing items and other information that the Legal Service Provider chooses to share with a User during the provision of services over our Platform;

• Parts of each Legal Service Provider’s public profile page, such as the Legal Service Provider’s first and last name, profile photo, law firm, work history, biography/description, city, practice areas, experience, ratings and reviews, are publicly visible to others. The Legal Service Provider’s precise location, calendar availability and other information may be shared where the Legal Service Provider has provided their consent;
  
• Any ratings and/or reviews about Deeded, the Platform, or a Legal Service Provider using Deeded’s Platform (via the Platform or any other third-party platform) are publicly visible to others; and

• Legal Service Providers may use our services and/or other third-party services to assist with managing their services or providing additional services requested by you, such as a calendar provider, accounting software, automated document generator software, legal practice management software, identity verification services, video conferencing software, document management platforms and document execution platforms. Legal Service Providers may use features on the Platform to exchange certain information about a User (such as organization name, file number, account number, general nature of matter) with us for the purposes of coordinating the delivery of services, with your express or implied consent. Legal Service Providers are solely responsible for third-party service providers they use and for ensuring those service providers process and maintain User information securely and in compliance with applicable law including, but not limited to, data privacy and data protection laws, professional codes of conduct or ethics, and law applicable to solicitor-client or lawyer-client privilege.

To help facilitate the services received by a User via the Platform and/or the User’s use of the Platform, Deeded may share certain information you have provided to us, including your personal information, with the Business Partners who are involved in your Transaction over our Platform, to the extent it is reasonably required to enable you to obtain services over our Platform and ensure adequate performance of the Services. This includes the following disclosure of information:

• A User’s personal information;

• The nature of the services provided by a Legal Service Provider to a User (consistent with your express or implied consent to the Legal Service Provider);

• The status of any services provided by a Legal Service Provider to a User (consistent with your express or implied consent to the Legal Service Provider);

• The status of the closing of a User’s purchase, sale or refinancing of real property;

• To the extent a User has provided consent, express or implied, to their Legal Service Provider, particulars of any services provided by a Legal Service Provider to a User, including but not limited to:

• Name of mortgage lender providing the User with mortgage funds;

• Address of real property purchased, sold or refinanced by a User;

• Whether any mortgage funds or closing funds have been received by a Legal Service Provider with respect to a User’s purchase, sale or refinancing of real property;
  
• Closing date pertaining to a User’s purchase, sale or refinancing of real property;

• Steps taken by a Legal Service Provider with respect to a User’s purchase, sale or refinancing of real property;

• The financial breakdown pertaining to a User’s purchase, sale or refinancing of real property; and

• Status as the approval of certain documents pertaining to a User’s purchase, sale or refinancing of real property.

Confidentiality

Each Legal Service Provider is obligated at all times to preserve the confidentiality of their clients’ information, whether disclosed to them over the Platform or otherwise, subject only to applicable law and that Legal Service Provider’s professional conduct obligations. Information that you share with your Legal Service Provider over the Platform for the purpose of obtaining legal services is subject to solicitor-client privilege.

Legal Service Providers’ duty of confidentiality, under applicable professional conduct rules, includes a duty not to disclose having been consulted or retained by you about your matter unless you provide consent (express or implied) to their doing so. The Legal Service Provider’s agreement to be retained for your matter is on the basis that you consent to their disclosing to us and to third parties from time to time that the Legal Service Provider is representing you in your matter and to their disclosing to us and to Deeded’s Business Partners a general description of the matter, for the purpose of facilitating the services you receive. Deeded and its Business Partners will not request, and the Legal Service Providers’ disclosure would not extend to, any sensitive information you provide to your Legal Service Provider or to any details you have not provided your consent to disclose.

For greater clarity, third-party Legal Service Providers using Deeded’s Platform are personally responsible for ensuring the confidentiality of information Users provide to the Legal Service Providers, consistent with their legal professional obligations. If you have any questions about how Legal Service Providers will use, protect, or disclose your information, please contact the Legal Service Provider directly.

Security

We regularly conduct security checks on all our resources, including software, hardware, and telecommunications equipment.

To ensure the security of processed information, we employ encryption for both data in transit and data at rest. We regularly conduct security audits, vulnerability scans, and penetration tests to ensure compliance with industry security practices and standards.

Prior to employment, all our employees, suppliers, and contractors undergo thorough security vetting. Our staff members receive comprehensive training on data protection and are fully aware of their responsibilities. These training sessions are conducted periodically, either on a regular schedule or on demand, with a minimum frequency of at least once per year.

We have implemented advanced measures in technical, administrative, and physical controls to safeguard Personal Information against unauthorized access, loss, misuse, interference, or alteration during its collection, use, disclosure, and storage. We restrict access to Personal Information only to individuals with a legitimate business need, aligning with the original purpose for which the information was provided.

Retention of Your Personal Information

After we have collected your personal information, we may retain a record of your personal information (including correspondence or comments). We will continue to use, maintain, transfer, disclose or retain your personal information for as long as necessary to fulfill the purposes for which it was collected and as required or permitted by law. However, we will take reasonable steps to destroy or permanently de-identify personal information we hold if it is no longer needed for our business purposes.

Cross-border Data Transfers

Sharing your personal information sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. To increase our efficiency, we use password- protected electronic file storage on cloud servers based outside of Canada, in countries where laws regarding collection, use, maintenance, transfer and disclosure of personal information may be less stringent than the laws in Canada. We do not assume any responsibility for the privacy practices, policies or actions of such cloud server providers or of any governmental authority of the country in which such cloud servers are based.

Control of, Access to, and Correction of, Your Personal Information

If you do not want your personal information collected, used, maintained, transferred, disclosed or retained by us as provided in this Privacy Policy, you should not use the Platform and you should refrain from: (a) registering for any specific tool or application that collects personal information; and (b) purchasing any product or service from us. Further, you may uninstall the Platform from your device using the standard uninstall process for your device. If you uninstall the Platform from your device, the unique identifier associated with your device will continue to be stored by us. If you re-install the Platform on the same device, we will be able to re-associate this identifier to your previous transactions and activities. You may also use tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the Platform. Lastly, devices have permission systems for specific types of device data and notifications, such as address book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Please note that changing such device settings may result in your loss of full functionality of the Platform.

You may request a copy of the personal information which you have provided to us by advising our Company’s Privacy Officer at privacy@deeded.ca. If you have any questions or enquiries relating to our privacy practices or procedures, or if you believe that the personal information that the Company holds about you is not accurate, complete or up to date, you may write to the Company’s Privacy Officer at privacy@deeded.ca. If you are able to establish that the information is not accurate, complete or up to date, we will take reasonable steps to correct the information so that it is accurate, complete and up to date. We may ask you to provide proof of identity before we can answer the above requests.

Non-Canadian Users

If you are located outside of Canada, please note that the information you provide to us will be used, maintained, retained, transferred and disclosed in Canada, where laws regarding use of personal information may be less stringent than the laws in your country. By using our Platform, you consent to such use, maintenance, retention, transfer and disclosure. You also consent to the adjudication of any disputes arising in connection with the Platform, this Privacy Policy and the Terms of Use in the Federal Court of Canada or the courts of the Province of Ontario, in accordance with Canadian federal law and Ontario law.

Questions or Comments

We welcome questions and comments about this Privacy Policy. If you wish to access, verify and/or amend your personal information or make a complaint under this Privacy Policy, please contact the Company’s Privacy Officer at: privacy@deeded.ca.