Privacy Policy

1. Who we are

AgentMind ("AgentMind", "we", "us", "our") is a software service operated from Ontario, Canada that helps licensed real estate professionals manage their client relationships, qualify leads, generate offers, match listings, and maintain regulatory compliance. This Privacy Policy describes how we handle personal information collected through the AgentMind platform - including agentmind.ca, the AgentMind dashboard at dash.agentmind.ca, and any AgentMind-hosted realtor website on a subdomain of agentmind.ca or a custom domain connected through our edge-network provider.

This policy applies to two distinct audiences:

• Realtors - licensed real estate professionals who sign up for AgentMind to manage their business. You are the "user" and "customer" of the service.
• End consumers - home buyers, sellers, tenants, and landlords whose information realtors enter into AgentMind (clients, leads, contacts). We process this information as an agent of the realtor; the realtor is the primary data custodian.

2. Personal information we collect

2.1 From realtors (account holders)

• Account credentials - email address, password (hashed using bcrypt; we never see the plaintext), full name, optional phone number.
• Professional identity - REBBA license number, brokerage name, brokerage address, designation (sales representative, broker, broker of record).
• Billing information - subscription plan, billing email, billing address. Credit card details are collected and stored directly by our payment processor; we never see or store your card number.
• Public website content - your bio, tagline, photo, custom domain, social handles, and neighborhood guides you publish on your AgentMind-hosted public site.
• Integration credentials - TRREB AMPRE bearer tokens (encrypted at rest), Google Calendar OAuth refresh tokens (encrypted at rest), Telegram chat ID (you link this manually).
• Phone numbers - provisioned through our telephony partner when you set up a business number, or your existing number if you port it in.
• Activity logs - login timestamps, IP addresses, device user-agent, AI service usage (counts and costs), audit trail of mutations on your account.

2.2 From end consumers (client / lead data realtors enter)

• Contact information - name, email, phone, company name (for corporate clients).
• Engagement criteria - budget, target areas, property type, bedrooms, square footage, financing status, timeline, notes.
• Conversation transcripts - incoming SMS, WhatsApp, and voice messages from leads (transcribed). These transcripts are encrypted with industry-standard symmetric encryption at the column level before storage.
• Documents - condo status certificates, offer terms, CMA reports, and buyer-comparison sheets generated for or about end consumers. Sensitive document text is encrypted at rest.
• Interaction history - logs of calls, emails, showings, and meetings the realtor records.

2.3 Information we do NOT store

• Original voice recordings. Telegram voice notes are streamed to our speech-to-text provider, transcribed, and discarded immediately. Only the text transcript is retained.
• Credit card numbers. All card data is collected and tokenized by our payment processor; we receive only a token and the last 4 digits for reference.
• MLS data outside of caching. We cache active listings for matching and your public site for up to 90 days, then purge.

3. How we use personal information

We use the information described in Section 2 to:

• Provide the AgentMind service (authentication, CRM, MLS matching, document generation, showing scheduling, billing).
• Run AI-assisted features (lead qualification, voice command parsing, offer drafting, CMA generation, status-certificate review, listing summarization). The AI providers we use are listed in Section 4 below.
• Send transactional notifications (lead alerts, showing reminders, billing receipts, security alerts) by email, SMS, or Telegram, based on your preferences.
• Maintain regulatory compliance (PIPEDA audit trail, REBBA disclosures on your public site, CREA Realtor Cooperation Policy 3-day MLS upload timer, RECO record-keeping support).
• Process payments and prevent fraud through our payment processor.
• Detect and respond to security incidents, abuse, and platform errors.
• Improve the service. Aggregate usage statistics (counts, latencies, error rates) may inform product decisions; we never use the content of your client or lead conversations for product improvement or AI model training.

We do NOT sell personal information to third parties. We do NOT use your data or your clients' data to train AI models - neither our own nor any third-party provider's.

4. Third parties we share information with (subprocessors)

To deliver the service, AgentMind shares limited personal information with the categories of subprocessors listed below. Each provider is bound by a data-processing agreement that restricts use to the purpose listed. We review this list when adding or changing providers. The exact identity of each provider is available on request to [email protected].

Category	Purpose	Region
Managed database + auth	Primary database, authentication, file storage	Canada (Toronto)
AI / language model provider	Lead qualification, offer drafting, CMA narrative, document review, voice command parsing	United States
Speech-to-text provider	Voice note transcription	United States
Payment processor	Payment processing, subscription management, invoicing	United States / Canada
Telephony provider	SMS, WhatsApp, voice number provisioning, voicemail transcription	United States
Transactional email provider	Account, billing, and notification emails	United States
Messaging platform	Realtor alerts and voice commands (opt-in by the realtor)	Various
Calendar provider	Two-way showing-calendar sync (opt-in via OAuth)	United States
Edge network + DDoS protection	DNS, DDoS mitigation, edge caching, custom-domain TLS for realtor sites	Global CDN
Mapping / geocoding provider	Address geocoding and map tile rendering on listing and engagement views	United States
MLS data feed	TRREB / CREA listing data under your IDX / DLA agreement	Canada
Error monitoring service	Application error reporting (no client conversation bodies; configured with PII redaction)	United States
Source code hosting	Code repository (no production customer data)	Australia

When a subprocessor in any of these categories is added or replaced, we update this table and the effective date at the top of this policy.

5. Where your data is stored (cross-border transfers)

Your primary account data - clients, engagements, interactions, documents, encrypted conversation transcripts - lives in our managed Canadian database hosted in the Toronto region. It does not leave Canada at rest.

In transit, certain operations route through subprocessors based in the United States (see Section 4). For example, when our AI features process a conversation, the relevant text is sent to our AI provider's US-based API, then the response is stored back in Canada. Similarly, SMS and voice traffic transits our telephony provider's US infrastructure, and payment data transits our payment processor.

Under PIPEDA, transferring personal information to a service provider outside Canada is permitted, but we must remain accountable for the information and ensure comparable protection. We do this through contractual data-processing agreements with each subprocessor and through architectural choices (column-level encryption, minimum-necessary data sharing, no model training).

6. Retention

• Active accounts - we retain your data while your subscription is active.
• Account deletion - when you delete your account (Settings → Delete account, or by emailing us), we purge your data within 30 days. Backups containing your data are overwritten on a 7-day rolling cycle.
• Audit logs and billing records - we retain authentication events, admin actions, and billing records for up to 7 years to meet legal and tax obligations. These do not contain client conversation content.
• Aggregated metrics - de-identified usage counts and timing data may be retained indefinitely for capacity planning.

7. Security

We protect personal information with industry-standard technical and organizational measures, including:

• TLS 1.2+ encryption for all data in transit (HTTPS everywhere).
• Column-level symmetric encryption for sensitive personal information at rest (lead conversations, interaction notes, offer terms, status certificate text, CMA narrative, client notes).
• Per-realtor data isolation enforced at the database layer - one realtor cannot access another realtor's data through the API even by mistake.
• Mandatory two-factor authentication (TOTP) on administrator accounts.
• IP allowlisting on the administrative console.
• Comprehensive audit logging of all authentication events and data mutations.
• Daily encrypted database backups with 7-day point-in-time recovery.
• Rate-limiting, intrusion detection, and dependency vulnerability auditing in CI.

No security system is perfect. If a breach occurs that creates a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by PIPEDA breach-reporting rules.

8. Your rights under PIPEDA

If you are a Canadian resident, you have the following rights with respect to your personal information:

• Right to access - you can request a copy of the personal information we hold about you. Realtors can export most of their data directly from the dashboard; for anything not exportable, email us.
• Right to correction - if information we hold is inaccurate, you can correct it directly in the dashboard or by writing to us.
• Right to deletion (right to be forgotten) - realtors can self-serve account deletion from Settings → Delete account, which purges identifiable data within 30 days. End consumers should contact the realtor who entered their information; the realtor can delete the relevant client / lead row, which removes it from our systems. We are happy to assist if a realtor is unresponsive.
• Right to withdraw consent - you can withdraw consent for non-essential processing at any time (for example, opt out of marketing emails). Withdrawing consent for essential processing means we can no longer provide the service and your account will be terminated.
• Right to complain - contact us first; we aim to resolve concerns directly. If we cannot resolve your concern, you can file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca.

To exercise any of these rights, email us at [email protected]. We respond within 30 days.

9. Cookies and tracking

AgentMind uses a small number of cookies that are essential to the service (authentication sessions, theme preferences, dismissed-notice flags). We do not currently use third-party analytics, advertising trackers, or social-media pixels on the dashboard or admin console. The marketing site may add lightweight, privacy-respecting analytics in the future; if we do, we will update the Cookie Policy and notify you on first visit.

10. Children

AgentMind is a B2B service for licensed real estate professionals. It is not intended for use by anyone under 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, contact us and we will delete it.

11. Changes to this policy

We may update this Privacy Policy from time to time - for example when we add a new subprocessor or feature that affects how we handle information. The "Last updated" date at the top of this page reflects the most recent change. For material changes that affect how your information is used, we will notify active customers by email before the change takes effect.

12. Contact

For any privacy-related question, request, or complaint, write to:

AgentMind
Privacy inquiries: [email protected]
General contact: [email protected]

Office of the Privacy Commissioner of Canada - for unresolved complaints: priv.gc.ca