Privacy Policy

Last updated: June 21, 2026

1. Who We Are

This platform provides AI-powered communication and lead-management software to licensed real estate professionals (each, an “Agency”). The Agency operating this instance of the platform is identified in the email signature and footer of every message you receive from us.

We process personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), the Personal Information Protection Act (BC PIPA), and Canada's Anti-Spam Legislation (CASL).

2. Information We Collect

We collect personal information that you provide directly, including:

  • Name, email address, and phone number
  • Property interests, timeline, budget, neighbourhood preferences, and other context shared in your inquiries
  • Messages you exchange with the Agency or our AI assistant, including email and SMS content
  • Records of your consent, including how and when you consented to receive communications
  • Identity verification information when transacting (handled through our partner ReallyTrusted, which is the system of record for FINTRAC identity verification, not stored in this platform)

3. How We Use Your Information

  • To respond to your inquiries about real estate services
  • To send you communications about properties, market updates, and relevant services from the Agency
  • To process and verify your identity when required by law (FINTRAC obligations for transactions involving real estate)
  • To improve the quality of our communications and services through analysis of message effectiveness
  • If a REALTOR® turns on voice personalization, to analyze that REALTOR's own past messages, with your identifying details filtered out, so the AI can draft in their writing style (see Section 4A)

4. Use of AI in Processing Communications

Disclosure required under PIPEDA and BC PIPA: We use artificial-intelligence systems (provided by Anthropic, an AI provider) to draft and assist with messages on behalf of the Agency. Your messages and lead context are processed by these systems to generate personalized responses. A licensed REALTOR® reviews and approves substantive communications before they are sent. The AI does not make legally binding decisions on the Agency's behalf.

4A. Voice Personalization (Optional: Learning a REALTOR's® Writing Style)

Some REALTORS® who use this platform choose to turn on voice personalization. This optional feature helps the AI draft messages that sound like your own REALTOR rather than generic. Here is how it works and what it means for your information.

  • What it does. When a REALTOR turns this on, the platform reads that REALTOR's own past outbound emails from their connected work mailbox (Microsoft 365 / Outlook) and analyzes their writing style (tone, sentence length, common phrases) so the AI can draft future messages in their voice. A licensed REALTOR® still reviews and approves substantive communications before they are sent (see Section 4).
  • It is your REALTOR's own sent mail, and it is optional. Only that REALTOR's own outbound messages are used, and only if they opt in. They can turn the feature off at any time, which stops any further learning.
  • We filter out your identifying information before any AI analysis. Before any email text leaves our servers, our system automatically scans it and removes the direct identifiers it detects, such as names, email addresses, phone numbers, and street addresses. No automated filtering is perfect, and some context in a message could still indirectly identify a person, so we reduce the personal information in the text to the lowest level we reasonably can, and we rely on the contractual safeguards below as a further layer of protection. We do not represent that this filtering is flawless. The goal is to learn your REALTOR's writing style, not your personal details, which is why we filter your identifying information out of the text first.
  • Our AI provider deletes it and does not train on it. The redacted text is processed by Anthropic, a service provider that processes data primarily in the United States (see Section 8 for how we handle information processed outside Canada). Anthropic is under a contract that prohibits using this text to train its models and requires it to be deleted within 30 days.
  • We do not sell it, and we do not use it to make decisions about you. Voice personalization affects only how a message is worded. It is never used to qualify, score, or make any decision about you, and the resulting style model is specific to one REALTOR and is not shared between agencies.
  • What we keep, and your choices. We retain the redacted text used to build a REALTOR's style model only as long as needed for that purpose. Because your messages to a REALTOR may incidentally appear in their sent mail, you may contact the Agency or the platform operator (Section 13) to ask that your correspondence be excluded from future voice personalization. A REALTOR can also turn voice personalization off at any time, which deletes all of the samples we hold for them. This does not affect your other rights in Section 10.

5. Data Received from Meta (Facebook + Instagram)

Applies only to real estate professionals who connect their Facebook Page or Instagram Business account to the platform. If you are a lead, past client, or other contact of an Agency, this section does not apply to you.

When a real estate agent connects their Facebook or Instagram Business account via our integration, we receive the following Platform Data from Meta’s Graph API:

  • The agent’s Facebook user ID, name, and email address (for identification of the connecting user)
  • The list of Facebook Pages the agent manages, including each Page’s never-expiring access token and (when linked) the connected Instagram Business account ID
  • Public post content and engagement metrics for the authorized Pages and Instagram Business accounts (likes, reactions, comments, shares, reach, impressions, saves)

We use Meta Platform Data only to:

  • Display post-performance analytics in the agent’s weekly performance report and on the Social Intelligence dashboard inside our platform
  • Calculate the 5-pillar content mix against the firm’s target content strategy

We do NOT:

  • Post on behalf of the agent or any user
  • Message any user via Meta channels
  • Run ads or otherwise transact financially with Meta
  • Share Meta Platform Data with any third party except the infrastructure providers disclosed in Section 7 (Vercel and Neon — both processors with contractual data-protection obligations)
  • Sell or rent Meta Platform Data to anyone
  • Use Meta Platform Data to train AI models. The AI models we use (Anthropic Claude) receive lead and conversation context, not the agent’s Meta data.

Token storage: Meta access tokens are encrypted at rest using AES-256 before being written to our database. They are decrypted only at the moment of use and never logged or transmitted to a third party.

Retention: Meta tokens and post-engagement data are retained for as long as the agent remains connected. When the agent disconnects through our app, or revokes our access at facebook.com/settings/business_tools, we delete the OAuth credentials within 24 hours. Aggregate analytics derived from the data may persist in an anonymized form for the agent’s historical performance report.

Deletion requests: see our User Data Deletion Instructions. Removing our app from your Facebook account triggers automatic deletion via Meta’s data-deletion callback.

6. Consent (CASL)

We send commercial electronic messages only with your express or implied consent. Express consent is recorded with a timestamp, source, and method. Implied consent applies to messages sent in direct response to your own inquiry within the timelines permitted by CASL.

You may withdraw consent at any time by:

  • Replying STOP to any SMS we send
  • Clicking the unsubscribe link in any email we send
  • Contacting the Agency at the address in the email signature

Unsubscribe requests are honoured within 10 business days as required by CASL.

7. Sharing Your Information

We share personal information only:

  • With the licensed real estate professionals at the Agency you contacted
  • With service providers we use to operate the platform, including our cloud hosting (Vercel), database (Neon), authentication (Clerk), AI provider (Anthropic), email delivery (Resend), per-agent Outlook mailbox access (Microsoft Graph), SMS provider (Twilio), background job processing (Inngest), product analytics (PostHog), and subscription billing (Stripe), plus identity verification (ReallyTrusted), each under contractual obligations to protect your information
  • With Meta (Facebook and Instagram) and LinkedIn, but only when a real estate professional has connected those accounts through our integration. In that case, we exchange OAuth credentials with the platform to fetch the professional’s own post analytics on their behalf. We do not push your lead or message data to Meta or LinkedIn.
  • When required by law, including to law enforcement or regulators such as FINTRAC, the BC Financial Services Authority (BCFSA), or the Canadian Real Estate Association

We do not sell your personal information to third parties.

8. International Data Transfers

Some of our service providers process information outside Canada (primarily the United States). We have contractual safeguards in place to ensure these providers handle your data with protection comparable to Canadian law. By using our services, you consent to these transfers.

9. Data Retention

  • Lead and conversation records: retained for as long as you remain a contact of the Agency, or as required by applicable law
  • CASL consent records: retained immutably so we can prove consent if challenged
  • FINTRAC-related records: retained for 5 years from the date of the relevant transaction, as required by federal law
  • Unsubscribe records: retained indefinitely so we honour your preference
  • Voice-personalization samples: the redacted text used to learn a REALTOR's writing style is kept only while that REALTOR has the feature turned on, and is deleted when they turn it off

10. Your Rights

Under PIPEDA and BC PIPA, you have the right to:

  • Access the personal information we hold about you
  • Request correction of inaccurate information
  • Withdraw consent (subject to legal or contractual obligations)
  • File a complaint with the Office of the Privacy Commissioner of Canada or the Office of the Information and Privacy Commissioner for British Columbia

To exercise these rights, contact the Agency directly using the information in their email signature, or contact the platform operator (see section 13).

11. Security

We protect personal information using industry-standard safeguards, including AES-256 encryption of credentials and OAuth tokens at rest, TLS encryption in transit, role-based access controls, and audited logging. Identity verification documents are stored exclusively in ReallyTrusted, never duplicated to this platform.

12. Cookies and Analytics

We use cookies only as needed to operate the platform, primarily for authentication. We do not use third-party advertising trackers. We do use a third-party product-analytics service (PostHog) to understand how the platform is used; that analytics data is keyed to professional-account and firm identifiers and is not intended to collect personal information from leads or past clients.

13. Contact and Complaints

For questions about this policy or requests to exercise your privacy rights, contact the Agency using the information in their email signature.

Privacy concerns about the platform itself can be sent to: privacy@krogelindustries.com

14. Changes to This Policy

We may update this policy. The “Last updated” date at the top reflects the most recent revision. Material changes will be communicated to active users via email.

This document is provided in good faith to satisfy disclosure obligations under PIPEDA, BC PIPA, and CASL. It does not constitute legal advice. Agencies operating on this platform are independently responsible for compliance with applicable law in their jurisdictions.

Privacy Policy · Krogel Capital