Privacy Policy

Effective Date: January 1, 2025

1. Introduction

This Privacy Policy describes how Centonis AI Inc. ("Company," "we," "us," or "our") collects, uses, discloses, and protects personal information in connection with RealtySnap ("RealtySnap" or the "Service"), a lead intelligence and automation platform for real estate professionals.

RealtySnap is a product operated by Centonis AI Inc., a corporation registered in British Columbia, Canada.

By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy.

2. Scope and Applicability

This Service is intended solely for business users (B2B), specifically real estate agents and brokers.

The Service is not intended for individuals under the age of 18, and we do not knowingly collect personal information from minors. Users must not use the Service to collect personal information from individuals under the age of 18.

3. Information We Collect

3.1 Account Information

When users create an account, we collect:

  • Email address (required)
  • Full name (from OAuth provider or user input)
  • Profile photo (from OAuth provider or optional upload)

Authentication is handled via Firebase Authentication, using Google OAuth, Microsoft OAuth, or email/password credentials.

Passwords are never stored in plain text.

3.2 Lead and Form Data (User-Generated Content)

Users may collect personal data from their own leads through custom forms they create, including:

  • Names
  • Email addresses
  • Phone numbers
  • Property addresses
  • Messages, notes, and free-text responses
  • Budget, timeline, preferences, and other qualification data
  • Property or listing interest information

External Lead Sources

Users may also receive leads through our External Lead Source integration, which allows users to connect third-party lead providers (such as Zillow, Realtor.ca, Realtor.com, and similar platforms) by forwarding notification emails to a unique inbound email address we provide.

When external lead notification emails are forwarded to your designated inbound email address:

  • We automatically parse the email content to extract lead information (name, email, phone, property interest, message)
  • The extracted data is stored as a lead in your account
  • We temporarily process the raw email content for parsing purposes
  • Original email content is stored with the lead record for reference

Important:

Users act as data controllers for lead data they collect. Users are solely responsible for:

  • Obtaining proper consent from their leads before collecting personal information
  • Ensuring compliance with all applicable privacy laws, including but not limited to PIPEDA, GDPR, CCPA, and CASL
  • Only forwarding legitimate lead notification emails from authorized sources
  • Ensuring they have the right to forward external lead notifications to our Service

3.3 AI Processing

We process lead data using artificial intelligence to:

  • Classify leads (e.g., Hot, Warm, Cold)
  • Assign confidence scores
  • Generate and send AI-assisted follow-up emails
  • Extract structured information from lead replies
  • Parse external lead emails to extract contact and property information

AI services are provided using Google Gemini 2.5 Flash models.

We do not use lead data to train proprietary AI models beyond providing the Service.

3.4 Usage and Analytics Data

We collect basic usage information to improve the Service, including:

  • Page views and navigation patterns
  • Feature usage statistics
  • Device and browser information
  • IP addresses (for security and analytics)

We use Google Analytics for this purpose. Analytics data is aggregated and does not identify individual leads. You may disable analytics tracking through your browser settings or browser extensions.

4. How We Use Information

We use information solely to:

  • Provide and operate the Service
  • Authenticate users
  • Store and manage leads
  • Perform AI classification and enrichment
  • Parse and process external lead notification emails
  • Send transactional and AI follow-up emails
  • Export data to user-configured integrations
  • Analyze usage patterns to improve the Service
  • Maintain security and prevent abuse
  • Comply with legal obligations

We do not sell personal data, share it with advertisers, or use it for unrelated purposes.

5. Data Ownership

You retain full ownership of all data you collect through the Service. We claim no ownership rights to user-generated content, including lead data, forms, emails, or files you upload. We process this data solely as a service provider on your behalf.

6. Integrations and Third-Party Access

6.1 Google Authentication and Google APIs

We use Google OAuth and Google APIs in compliance with Google API Services User Data Policy.

Google Sheets Integration

Access: Read and write

Scopes used:

  • https://www.googleapis.com/auth/spreadsheets - Read and write spreadsheet data
  • https://www.googleapis.com/auth/drive.readonly - List user's spreadsheets for selection
  • https://www.googleapis.com/auth/drive.file - Create new spreadsheets
  • https://www.googleapis.com/auth/userinfo.email - Identify user's Google account

Purpose:

  • List spreadsheets (so you can choose where to export)
  • Create or update spreadsheets you select
  • Export lead data to spreadsheets you designate

Data Handling:

  • We do not store Google Sheets content on our servers
  • Data passes through our systems transiently for export only
  • We do not read spreadsheet content; we only write lead data to sheets you select
  • OAuth tokens are encrypted and stored securely for integration continuity
  • We only access Google Sheets when you explicitly initiate an export action

Limited Use Disclosure

RealtySnap's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

  • We only request the minimum scopes necessary to provide the Google Sheets export functionality
  • We access Google Sheets only when you explicitly initiate an export action
  • We do not use Google user data for serving advertisements
  • We do not allow humans to read Google user data unless: (a) we have your explicit consent for support purposes, (b) it is necessary for security purposes (e.g., investigating abuse), or (c) it is required to comply with applicable law
  • We do not transfer Google user data to third parties except: (a) as necessary to provide the Service (exporting to your chosen spreadsheet), (b) with your explicit consent, (c) for security purposes (e.g., fraud prevention), or (d) as required by law

6.2 Microsoft Excel Online

We export lead data to Excel Online using Microsoft Graph API.

Microsoft Excel Online Integration

Access: Read and write

Scopes used:

  • Files.ReadWrite - Export lead data to Excel workbooks in your OneDrive
  • User.Read - Identify your Microsoft account
  • offline_access - Maintain connection without requiring re-authentication

Purpose:

  • Export lead data to Excel Online workbooks you specify
  • Create or update Excel files in your OneDrive
  • Access workbooks you designate for lead data export

Data Handling:

  • We do not store Excel workbook content on our servers
  • Data is transmitted directly to your selected workbooks
  • We do not read workbook content; we only write lead data to files you select
  • OAuth tokens are encrypted and stored securely for integration continuity
  • We only access Excel files when you explicitly initiate an export action

6.3 Zapier

Users may send lead data via webhooks to Zapier. Data is transmitted directly to user-configured workflows and not retained by us.

6.4 Follow Up Boss

Users may sync lead data to Follow Up Boss using user-provided API keys.

7. Email Communications

7.1 Transactional Emails to Users

We send essential emails for service operation:

Lead Notifications

  • Sent from: hello@realtysnap.ca via Resend
  • Purpose: Notify you when new leads are submitted
  • Required for service operation

Account and Security Notices

  • Sent from: hello@realtysnap.ca via Resend
  • Purpose: Account updates, security alerts, service updates
  • Required for service operation

7.2 AI Follow-Up Emails to Leads

AI-generated emails sent on behalf of users:

  • Sent from hello@realtysnap.ca via Resend
  • Used to collect missing qualification data
  • Include an unsubscribe link in every message
  • CASL-compliant
  • Use user-specific reply aliases (e.g., phils-team-7km@realtysnap.ca)

We honor all unsubscribe requests automatically.

7.3 Support and Inquiries

For support requests, account inquiries, or general correspondence: Email: realtysnap@outlook.com. This is our human support channel for assistance.

8. Cookies and Tracking

We use the following types of cookies:

Essential Cookies (Required)

  • Authentication and session management
  • Required for login and service functionality

Analytics Cookies (Optional)

  • Google Analytics for usage statistics and service improvement
  • Track page views, feature usage, and navigation patterns
  • You may disable these through browser settings or browser extensions

We do not use advertising or third-party tracking cookies.

9. Third-Party Service Providers (Subprocessors)

We use the following third-party service providers who may process data on our behalf:

  • Google Cloud Platform (Firebase) - Data storage, authentication, AI processing (Firestore, Firebase Auth, Firebase Storage)
  • Resend - Email delivery for transactional emails and AI follow-ups
  • Stripe - Payment processing
  • Google Analytics - Usage analytics (optional, can be disabled by users)
  • Vercel - Application hosting and content delivery

All subprocessors are bound by strict data protection obligations.

10. Data Storage and Security

  • Database Hosting: Google Cloud Platform (Firebase Firestore)
  • Application Hosting: Vercel
  • Region: United States (us-central1 for Firebase services)
  • Encryption: At rest (AES-256) and in transit (TLS 1.2+)
  • Access Controls: Role-based access, multi-factor authentication
  • Token Security: Secure, encrypted storage of OAuth and API tokens

While we implement industry-standard security measures, no system is completely secure. You are responsible for maintaining the confidentiality of your account credentials.

11. Data Retention and Deletion

11.1 Active Accounts

We retain your data for as long as your account is active and as needed to provide the Service.

11.2 Account Deletion

When you delete your account:

  • All account data, leads, forms, files, integrations, and AI session data are immediately and permanently deleted
  • No backups or retention period apply
  • Deletion is irreversible

11.3 Inactive Accounts

If your account remains inactive (no login) for 12 consecutive months:

  • We will send a warning email to your registered email address
  • If you do not respond or log in within 30 days of the warning, your account and all associated data will be permanently deleted
  • You can prevent deletion by logging in at any time

12. Data Breach Notification

In the event of a data breach that affects your personal information, we will notify you within 72 hours of becoming aware of the breach, in accordance with applicable law. Notification will be sent to your registered email address and will include:

  • Nature of the breach
  • Data affected
  • Steps we are taking to address the breach
  • Recommended actions you should take

13. Your Rights

You have the right to:

  • Access your data and receive a copy
  • Correct inaccuracies in your information
  • Delete your account and all associated data
  • Export data via integrations (Google Sheets, Excel, Zapier)
  • Withdraw consent by disconnecting integrations
  • Object to certain processing activities

To exercise these rights, you may use your account settings or contact us at realtysnap@outlook.com.

13.1 Additional Rights for EU Users (GDPR)

If you are located in the European Union, you have additional rights under GDPR:

  • Right to data portability - Receive your data in a structured, commonly used format
  • Right to restrict processing - Request limitation of how we process your data
  • Right to object - Object to processing based on legitimate interests
  • Right to lodge a complaint - File a complaint with your local data protection authority

13.2 Additional Rights for California Users (CCPA)

If you are a California resident, you have additional rights under CCPA:

  • Right to know - Request disclosure of categories and specific pieces of personal information collected
  • Right to delete - Request deletion of personal information
  • Right to opt-out - Opt out of the sale of personal information (note: we do not sell personal information)
  • Right to non-discrimination - Not receive discriminatory treatment for exercising your rights

To exercise CCPA rights, contact us at realtysnap@outlook.com.

14. International Users and Data Transfers

We primarily operate in Canada but serve users internationally.

Data Processing Location: User data is stored and processed in the United States (Google Cloud Platform, us-central1 region for Firebase services; Vercel for application hosting).

International Transfers: By using the Service, you acknowledge and consent to the transfer of your data to the United States. We apply GDPR-consistent safeguards, including:

  • Standard Contractual Clauses with subprocessors
  • Adequate technical and organizational security measures
  • Compliance with applicable data protection regulations

If you are located in the EU, UK, or other jurisdictions with data transfer restrictions, your use of the Service constitutes consent to this transfer.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

Notice of Material Changes: We will notify you of material changes by:

  • Sending an email to your registered email address at least 30 days before the changes take effect
  • Posting a prominent notice on the Service

Your Continued Use: Your continued use of the Service after changes take effect constitutes acceptance of the updated Privacy Policy.

Review History: The effective date at the top of this policy indicates when it was last updated.

16. Contact Information

Centonis AI Inc.

Operating product: RealtySnap

Email: realtysnap@outlook.com

Address: 4843 55B Street, Delta, BC V4K 3V7, Canada

Website: https://realtysnap.ca

For privacy-related inquiries, data subject requests, or any questions about this Privacy Policy, please contact us at the email address above.

Last Updated: January 1, 2025

RealtySnap's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

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