Legal

Privacy Policy

Effective date: June 25, 2026. This policy applies to RealESimple Inc. ("RealESimple", "we", "us") and the real-e. platform at realesimple.com.

We are committed to protecting your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

1. Information We Collect

We collect personal information that is necessary to operate the platform and facilitate real estate auctions.

Account & identity

  • Full name, email address, and password
  • Phone number (collected and verified via two-step OTP)
  • Profile photo (optional)
  • Consent records (timestamped, immutable)

Bidder verification

  • Financial proof of funds (PDF or image, stored privately)
  • Approved maximum bid amount set by our team after document review
  • Device fingerprint — a non-personally-identifiable technical signal used to detect fraud and account abuse

Seller information

  • Property address, type, size, and detailed attributes
  • Desired pricing and strategy preferences
  • Seller disclosures (SPIS-style questions)
  • Property photos and virtual tour links
  • Agent and financing details submitted during auction registration

Auction activity

  • Bid amounts, timestamps, and auction registrations
  • Proxy (auto) bid maximums
  • IP address and browser information at time of bidding

Communications

Records of emails and SMS messages sent to you through the platform, including notifications about bids, auction status, and account actions.

2. How We Use Your Information

We use your personal information only for purposes a reasonable person would consider appropriate given the context:

  • Creating and managing your account
  • Verifying your identity and eligibility to bid or list
  • Facilitating live and proxy bidding in auctions
  • Reviewing seller submissions and approving listings
  • Sending transactional notifications (bid updates, auction results, status changes)
  • Detecting and preventing fraudulent activity
  • Complying with legal obligations and resolving disputes
  • Improving the platform through aggregate, anonymized analytics

We do not sell your personal information. We do not use it for third-party advertising.

3. Legal Basis & Consent

We collect and process your personal information with your knowledge and consent, which you provide when you create an account and agree to these terms. Where we rely on consent, you may withdraw it at any time by contacting us — though withdrawal may limit your ability to use certain features of the platform.

In some cases, we may process information without consent where permitted by law, such as for fraud investigation or to comply with a legal requirement.

4. How We Share Your Information

We do not sell or rent personal information. We share it only in the following limited circumstances:

Service providers

We use trusted third-party services to operate the platform. Each provider processes data only as directed by us:

  • Supabase (database, authentication, file storage) — hosted in the United States
  • Resend (transactional email delivery)
  • Twilio (phone number verification and SMS notifications)
  • Vercel (web hosting and serverless functions)
  • ThumbmarkJS (device fingerprinting for fraud detection)

Legal disclosure

We may disclose personal information to law enforcement or regulatory bodies where required by law, court order, or to protect the rights and safety of our users or the public.

Business transfers

In the event of a merger, acquisition, or sale of assets, personal information may be transferred as part of that transaction. We will notify affected users via email prior to any such transfer.

5. Cross-Border Transfers

Some of our service providers are located in the United States. By using the platform, you acknowledge that your information may be processed in jurisdictions outside of Canada where privacy laws may differ. We require all providers to maintain safeguards consistent with Canadian privacy standards.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected and to comply with legal obligations:

  • Active account data is retained for as long as your account is open
  • Auction and bid records are retained for a minimum of 7 years for legal and regulatory compliance
  • Financial proof of funds documents are retained for 2 years after the related auction closes
  • Consent records are retained indefinitely as required by law
  • Closed accounts are anonymized within 90 days of deletion request, subject to legal hold exceptions

7. Security

We implement industry-standard safeguards to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These include encrypted data transmission (TLS), access controls, row-level security on our database, and private storage buckets for sensitive documents.

No method of transmission or storage is 100% secure. If you become aware of any security concern related to your account, please contact us immediately at privacy@realesimple.com.

8. Cookies & Device Fingerprinting

We use session cookies set by Supabase to maintain your authenticated session. These are strictly necessary for the platform to function and are not used for tracking or advertising.

We also collect a device fingerprint — a hash derived from non-personally-identifiable browser and device signals — solely to detect fraudulent account creation and bid manipulation. This hash is stored on your profile and is not shared with third parties for any other purpose.

9. Your Rights

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

  • Know what personal information we hold about you
  • Access your personal information and receive a copy
  • Correct inaccurate or incomplete information
  • Withdraw consent for non-essential processing
  • Request deletion of your account and personal data (subject to legal retention obligations)
  • Lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC)

To exercise any of these rights, contact our Privacy Officer at privacy@realesimple.com. We will respond within 30 days.

10. Children's Privacy

The real-e. platform is intended for adults aged 18 and older. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us with personal information, please contact us and we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the effective date at the top of this page and, where changes are material, notify registered users by email. Continued use of the platform after changes are posted constitutes acceptance of the updated policy.

12. Contact Us

If you have questions or concerns about this Privacy Policy or our privacy practices:

Privacy Officer — RealESimple Inc.

Email: privacy@realesimple.com

Ontario, Canada

You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada.