Vicinus Privacy Policy

This Privacy Policy explains how Vicinity PropTech Inc., operating as “Vicinus” (“Vicinus”, “we”, “us”), collects, uses, discloses, and protects personal information in connection with the Vicinus websites, applications, and services (the “Platform”). We handle personal information in accordance with the Personal Information Protection Act (British Columbia) (“PIPA”) and, where applicable, the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”).

1. Our Privacy Commitments

Four commitments shape how the Platform handles your information:

• You choose who to contact. We share your identity and contact details with a real estate professional only when you choose to contact that professional. We never sell your personal information, and we do not sell or rent leads.
• No intent profiling. We do not create or provide scores, ratings, tiers, or assessments of your intent or likelihood to transact, and we do not disclose your browsing or search activity to real estate professionals. This does not change with consent settings; we do not offer it at all.
• Professionals see aggregates only. Professionals receive aggregated, de-identified statistics about overall activity in a neighbourhood, produced with minimum group sizes and at neighbourhood or zone level so that individuals cannot be identified. They never see your identity, your saved items, or your individual activity.
• Sharing with your agent is yours to control. If you link your account to a professional you have chosen, you decide what is shared and can revoke it at any time.

2. Information We Collect

Information you provide

• Account information: name, email address, password, and optional profile details.
• Preferences you create: saved searches, saved neighbourhoods, saved listings, filters, and alert settings.
• Inquiries you send: the message you write and the contact details you provide when you choose to contact a real estate professional or listing brokerage, and messages you send to us through contact forms.
• Search preferences derived from your own activity, including the areas and property types you search for or inquire about, which we record on your account to personalize your search experience.
• Sharing settings: if you link your account to a professional, the fact of that link and what you have chosen to share.
• Professional account information: for licensed professionals, licence and brokerage details, billing contact information, content submitted for publication, and client records they choose to import (which they control and for which they are accountable). Payment card details are processed by our payment processor and are not stored by Vicinus.
• Event features: where offered, such as open-house check-in tools used by professionals, information is collected only with the notice and consent required by PIPA.

Information collected automatically

• Usage information: pages and listings viewed, searches performed, features used, and interactions with content.
• Device and log information: IP address, browser and device type, operating system, referring pages, and timestamps.
• Approximate location: derived from IP address or, with your permission, from your device, to show relevant listings and neighbourhoods.
• Cookies and similar technologies, as described below.

3. How We Use Personal Information

We collect, use, and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances, including to:

• provide, operate, and secure the Platform, including accounts, search, saved items, and the alerts you set up;
• deliver inquiries you choose to send to a real estate professional or listing brokerage, and keep records that they were delivered;
• communicate with you about your account and the Platform, and send marketing communications where permitted by law and, where required, with your consent (you can unsubscribe at any time);
• produce aggregated, de-identified analytics about Platform usage and market interest, which we may make available to professionals and developers as market intelligence, and use to improve the Platform;
• process subscription payments, prevent fraud and abuse, and enforce our terms; and
• comply with legal obligations, including data licensing obligations to the Canadian Real Estate Association and real estate boards.

4. How We Handle Your Inquiries

When you choose to contact a professional, we deliver your message and the contact details you provided to the recipient you selected, by email, complete and unaltered. We do not retain the content of your message or the contact details you provided after delivery. We keep a delivery record showing which placement or content the inquiry came from, the recipient, the time, and confirmation that it was delivered, so that we can confirm delivery, resolve disputes, prevent abuse, and meet our legal obligations. Professionals are shown a notification that an inquiry has been delivered which identifies the placement or content it came from and does not disclose your identity. We do not provide professionals with an inquiry inbox, management, status tracking, ranking, scoring, or bulk-export tools, and we do not analyze your inquiry to characterize you.

5. Aggregated and De-identified Information

We produce aggregate statistics about activity on the Platform, such as how interest in a neighbourhood is trending or what property types people in an area search for, and we make these available to professionals and developers. These outputs are produced with minimum group sizes and at neighbourhood or zone level, are not broken down to a street, building, or household, and are not combined with information that would allow an individual to be identified. Aggregate outputs describe activity on the Platform and are not statements about any individual or about the population of an area.

6. Consent

We collect, use, and disclose personal information with your consent, except where PIPA or PIPEDA permits or requires otherwise. Consent may be express (for example, when you submit an inquiry, or link your account to a professional) or implied where the purpose is obvious and you voluntarily provide the information (for example, providing an email address to receive an alert you requested). You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice; withdrawing consent may limit the features we can provide.

7. When We Share Personal Information

We do not sell personal information. We share it only:

• With the professional you choose. When you contact a professional or listing brokerage, we deliver your inquiry and contact details to that recipient. Inquiries about a specific MLS® listing sent through listing contact features are delivered to the listing brokerage or listing agent. Once received, the professional's handling of your information is governed by their own and their brokerage's privacy practices and obligations under PIPA.
• With a professional you have linked. If you link your account to a professional and choose to share saved items, we provide what you selected, for as long as you leave the link active.
• With service providers. We use third-party providers for cloud hosting and infrastructure, search, mapping, email delivery, analytics, and payment processing. They may access personal information only to perform services for us and must protect it. Some providers store or process information outside Canada, including in the United States.
• For legal reasons. Where required or permitted by law, including to comply with a subpoena, court order, or lawful request by a governmental authority, to enforce our terms, or to protect the rights, property, or safety of Vicinus, our users, or others.
• Business transactions. In connection with a prospective or completed business transaction such as a financing, merger, or sale of assets, subject to appropriate confidentiality protections and, where required, notice.

8. Professionals' Client Data

Professionals using our paid tools may import their own client records. Where they do, the professional is the organization accountable for that information under PIPA and Vicinus acts only as their service provider, processing it on their instructions to provide the tools they subscribe to. We do not combine a professional's imported client data with Platform activity or identity information, and we do not use it for any other professional or purpose. If you are a client of a professional and wish to access or correct information they have provided to us, please contact the professional directly.

9. Storage Outside Canada

Vicinus is based in British Columbia. Personal information may be stored and processed on servers located outside Canada (including in the United States) by our cloud infrastructure and service providers. While outside Canada, information is subject to the laws of those jurisdictions, and courts, law enforcement, and national security authorities there may be able to access it under local law. We use contractual and technical safeguards designed to provide comparable protection wherever information is processed.

10. Cookies and Analytics

We use cookies and similar technologies to keep you signed in, remember preferences, measure Platform performance, and understand how the Platform is used. You can control cookies through your browser settings; disabling certain cookies may affect Platform functionality. Where we use third-party analytics, data is used to produce aggregated usage insights and is not used to build individual profiles for real estate professionals.

11. Retention

We retain personal information only as long as necessary for the purposes described in this policy or as required by law. Message content and contact details you submit in an inquiry are not retained after the inquiry is delivered. Delivery records are retained for a limited period for delivery confirmation, dispute resolution, abuse prevention, and legal obligations. Information used to make a decision that directly affects you is retained for at least one year after the decision, as required by PIPA. Saved searches, alerts, and sharing links are deleted when you delete them or your account, subject to routine backup cycles. We de-identify or securely destroy information when it is no longer required.

12. Security

We protect personal information with security safeguards appropriate to its sensitivity, including encryption in transit, access controls, and administrative and technical measures designed to prevent unauthorized access, collection, use, disclosure, copying, modification, or disposal. No system is perfectly secure; if a breach creates a real risk of significant harm, we will notify affected individuals and regulators as required by law.

13. Your Rights

Subject to limited exceptions under PIPA and PIPEDA, you may:

• request access to the personal information we hold about you and information about how it has been used and disclosed;
• request correction of inaccurate or incomplete information;
• withdraw consent, unsubscribe from marketing, revoke a sharing link, and delete your saved items or your account; and
• ask questions or make a complaint about our privacy practices.

We will respond to written access requests within the timelines required by PIPA (generally 30 days). We may need to verify your identity before acting on a request.

14. Children

The Platform is intended for adults and is not directed to individuals under the age of majority. We do not knowingly collect personal information from minors; if you believe a minor has provided personal information to us, contact us and we will delete it.

15. Changes to This Policy

We may update this policy from time to time. Material changes will be communicated by posting the updated policy with a new effective date and, where appropriate, by additional notice. Continued use of the Platform after the effective date constitutes acceptance to the extent permitted by law; where a new purpose requires fresh consent, we will seek it.

16. Contact Us — Privacy Officer

Vicinus has designated a Privacy Officer accountable for compliance with this policy and applicable privacy law. Questions, access requests, correction requests, and complaints may be directed to: Privacy Officer, Vicinity PropTech Inc. (operating as Vicinus), British Columbia, Canada; Email: info@vicinityproptech.com.

If you are not satisfied with our response, you may contact the Office of the Information and Privacy Commissioner for British Columbia (oipc.bc.ca) or, where PIPEDA applies, the Office of the Privacy Commissioner of Canada (priv.gc.ca).