Privacy Policy

1. Who We Are

EstatePulse Inc.(“EstatePulse,” “we,” “us,” or “our”) operates the EstatePulse real estate platform located at estatepulse.ca. We are headquartered at Toronto, Ontario, Canada.

This policy explains how we collect, use, disclose, and safeguard personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

2. Information We Collect

We collect personal information you provide directly and information generated through your use of our platform:

• Identity: Full legal name, date of birth, government-issued ID (for KYC verification)
• Contact: Email address, phone number, mailing address
• Financial: Bank account details (via Stripe Financial Connections), income information, source of funds declarations
• Transaction: Offer amounts, deal terms, escrow records, document signatures
• Residency & citizenship: Required under Canadian law to enforce the Prohibition on the Purchase of Residential Property by Non-Canadians Act
• Usage data: Pages visited, search queries, device type, IP address
• Communications: Messages sent through our platform

3. How We Use Your Information

• To provide, maintain, and improve our platform
• To verify your identity as required by FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act
• To process real estate transactions and escrow deposits
• To generate legally required documents (Agreement of Purchase and Sale, FINTRAC Client Information Record)
• To communicate with you about your account, deals, and legal requirements
• To detect and prevent fraud and money laundering
• To comply with Ontario real estate regulations (REBBA 2002, RECO requirements)
• To comply with our legal obligations as a reporting entity under PCMLTFA

4. Legal Basis for Processing

We rely on the following bases to process your personal information:

• Your consent: Collected at account creation and for optional features (marketing emails, SMS)
• Contract performance: To fulfil our obligations when you use the platform to conduct a real estate transaction
• Legal obligation: FINTRAC reporting, PCMLTFA compliance, Ontario real estate legislation, Foreign Buyer Ban compliance
• Legitimate interest: Fraud prevention, platform security, product improvement

5. Disclosure of Your Information

We may disclose your personal information to:

• Transaction parties: Your assigned trust organization (law firm, trust company, or title agent) and their staff for closing purposes
• Identity verification: Persona (our KYC provider) for government ID verification and sanctions screening
• Payment processing: Stripe for bank account verification and payment processing
• FINTRAC: We are required by law to report certain transactions and suspicious activity
• Law enforcement: Where required by court order, subpoena, or applicable law
• Service providers: Supabase (database/storage), Resend (email), Sentry (error monitoring) — each bound by data processing agreements

We do not sell your personal information to third parties.

6. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes described in this policy, subject to the following minimum retention periods:

• FINTRAC records: 5 years from the date of the last business relationship or transaction (PCMLTFA s.6)
• Transaction records: 7 years for accounting and tax purposes
• KYC verification: Duration of relationship plus 5 years
• Account data: Until account deletion, plus applicable statutory periods

7. Your Rights

Under PIPEDA and applicable law, you have the right to:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Withdrawal of consent: Withdraw consent for non-essential processing (note: withdrawal may affect your ability to use certain features)
• Deletion: Request deletion of your personal information, subject to retention obligations (FINTRAC-locked records cannot be deleted during the 5-year retention period)
• Complaint: Lodge a complaint with the Office of the Privacy Commissioner of Canada (priv.gc.ca)

To exercise any of these rights, contact us at privacy@estatepulse.ca. We will respond within 30 days.

8. Security

We use industry-standard technical and organizational safeguards including encryption at rest and in transit, role-based access controls, multi-factor authentication for privileged operations, time-limited document access URLs, and regular security reviews. No system is completely secure; if you believe a security incident has occurred, contact us immediately at privacy@estatepulse.ca.

9. Cookies & Tracking

We use essential cookies to maintain your session and security. We use analytics cookies (where you have consented) to understand how the platform is used. See our Cookie Policy for details.

10. International Transfers

Some of our service providers (Supabase, Stripe, Persona, Sentry) may process data in the United States or other jurisdictions. Where data is transferred outside Canada, we ensure appropriate contractual protections are in place consistent with PIPEDA accountability principles.

11. Changes to This Policy

We may update this policy from time to time. Material changes will be communicated via email and an in-app notice at least 30 days before they take effect. Your continued use of the platform after changes take effect constitutes acceptance of the updated policy.

12. Contact Us

Our Privacy Officer can be reached at:

This policy was last reviewed by legal counsel and approved for publication on May 1, 2026. Pending final legal review before production launch — do not treat as legal advice.