1. Introduction
MINAS Technologies Inc. ("we", "us", or "our") operates HomeTrack Market (the "Platform"), a Canadian real estate marketplace. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use the Platform.
We are committed to complying with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation in Canada.
2. Personal Information We Collect
We collect the following types of personal information:
• **Account Information** — your name, email address, phone number, and password (encrypted).
• **Identity Verification** — government-issued photo ID documents uploaded for verification purposes.
• **Property Information** — listing details, photos, proof of ownership documents, and Property Passport content (notes, documents, voice recordings).
• **Offer Information** — offer amounts, messages to sellers, and pre-qualification answers.
• **Transaction Information** — lawyer contact details, deposit proof, mortgage approval letters, inspection reports, and signed agreements uploaded to the Transaction Tracker.
• **Agent Information** — REALTOR® profile details, brokerage information, CREA/DDF® credentials, and agent-uploaded documents.
• **Usage Data** — search queries, favorites, property views, and interaction logs used to improve the Platform.
• **Location Data** — approximate location used for map-based search and nearby professional recommendations, with your consent.
3. How We Use Your Information
We use your personal information to:
• Create and manage your account
• Verify your identity and ownership of listed properties
• Display listings and facilitate communication between Buyers, Sellers, and Agents
• Process the $25 platform fee and activate the Transaction Tracker
• Send you notifications about offers, listings, announcements, and transaction updates
• Power AI-assisted tools (Listing DNA Agent, Seller Net Sheet, Buyer Assistant) using your listing and offer data
• Recommend nearby lawyers and home inspectors based on your location
• Prevent fraud, enforce our Terms of Use, and comply with legal obligations
• Improve our services and develop new features
4. Sharing Your Information
We share your personal information in the following circumstances:
• **Between Buyers and Sellers (or Agents)** — when a Seller pays the $25 fee to unlock a Buyer's contact details, the Buyer's name, email, and phone number are shared with the Seller. Similarly, seller contact details are shared with the buyer when appropriate.
• **Between Transaction Parties** — lawyer contact information, deposit proof, mortgage letters, and inspection reports are shared between the parties involved in a Transaction Tracker.
• **With Lawyers** — a Deal Summary is emailed to both parties' lawyers upon completion of a transaction.
• **With Service Providers** — we use third-party services such as Stripe (payment processing), Google (maps, AI, email), and cloud hosting providers. These providers process data on our behalf and are bound by confidentiality obligations.
• **With CREA/REALTOR.ca** — DDF® listing data is displayed with attribution as required by CREA rules. Agent profile information (name, brokerage) is displayed publicly on DDF® listings.
• **As Required by Law** — we may disclose information if required by law, court order, or government authority.
5. Data Retention
We retain your personal information for as long as your account is active and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce our agreements.
Identity verification documents are retained for the duration of your account and may be kept for up to 7 years after account closure to comply with anti-fraud and legal requirements.
You may request deletion of your account and personal data at any time by contacting support. Certain information may be retained where required by law.
6. Data Security
We use industry-standard security measures to protect your personal information, including encrypted password storage, secure file upload, and access controls. Identity verification documents and transaction documents are stored in access-controlled cloud storage.
Despite these measures, no system is completely secure. We cannot guarantee the absolute security of your data. You are responsible for keeping your account credentials confidential.
7. Cookies and Tracking
The Platform uses cookies and similar technologies to maintain your session, remember preferences, and analyze usage patterns. You can control cookies through your browser settings, but disabling them may affect functionality.
We may use analytics services to understand how users interact with the Platform and to improve our services.
8. AI and Automated Processing
We use artificial intelligence to power features such as the Listing DNA Agent, Seller Net Sheet AI, and Buyer Assistant. These tools process your listing data, Property Passport content, and conversation history to generate responses.
AI-generated content is not reviewed by humans before display. We do not use your personal information to train external AI models. Your data is used solely to provide the Platform's features to you.
9. Your Privacy Rights
You have the right to:
• **Access** — request a copy of the personal information we hold about you
•**Correct** — request correction of inaccurate or incomplete information
• **Delete** — request deletion of your account and personal data, subject to legal retention requirements
• **Withdraw Consent** — withdraw consent for location data collection and certain processing activities
• **Complain** — file a complaint with the Office of the Privacy Commissioner of Canada if you believe we have mishandled your information
To exercise these rights, contact us through the Help button in the app or via the Contact page.
10. Children's Privacy
The Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, please contact us and we will delete it.
11. Third-Party Links
The Platform may contain links to third-party websites (e.g., REALTOR.ca, lawyer directories, inspector directories). We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing personal information.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify users of material changes through the Platform or by email. Continued use of the Platform after changes are posted constitutes acceptance of the updated policy.
13. Contact
If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us through the Help button in the app or via the Contact page.