Privacy Policy.

This Privacy Policy (“Policy”) describes how TrueTenant Inc. (“TrueTenant,” “we,” “our,” or “us”) collects, uses, stores, discloses, and protects your personal information in connection with our tenant screening, reusable tenant profile, property management and related services (the “Services”). We are committed to safeguarding personal information in accordance with applicable Canadian privacy laws.

By creating an account and reusable tenant profile (“Profile”) with TrueTenant, you acknowledge that we will collect, retain, and use your personal information as described in this Policy. Consent to this collection and retention is a mandatory condition for using the Services. If you do not consent to these practices, you must not create or maintain a Profile.

For the purposes of this Policy:

• “Personal Information” means information about an identifiable individual, as defined under applicable Canadian privacy laws. This includes any information that can identify you directly or indirectly (for example, your name, address, date of birth, contact information, identification numbers, etc.).
• “Profile” means the reusable tenant profile created and maintained on the TrueTenant platform, including the TrueTenant Score and all related data about a User.
• “User” means any individual who creates a Profile on the TrueTenant platform (also referred to as “you” in this Policy).
• “Landlord” or “Property Manager” means a third party to whom a User’s data may be disclosed via the Services for the purpose of evaluating rental applications.
• “Services” refers to the tenant screening, Profile management, property management, and related services and applications provided by TrueTenant.

TrueTenant may collect and process the following categories of Personal Information from Users:

3.1 Identity and Contact Information

This includes your full name, date of birth, current address, email address, phone number, government-issued identification details (e.g. driver’s license or passport number), biometric photographs or video for identity verification, residency or citizenship status, and any related verification data.

3.2 Financial Information

Information used to assess creditworthiness and income, such as credit reports and scores obtained from credit bureaus (e.g. Equifax), banking and income data obtained via services like Flinks (account balances, transaction history, employment income), tax documents (T4 slips, Notices of Assessment), and other financial records relevant to rental applications.

3.3 Rental History

Your current and past rental information, including references from previous landlords or property managers, records of rent payment history, and related tenancy data. Where available, TrueTenant also provides a link to the applicant’s public Landlord and Tenant Board (LTB) records. TrueTenant provides the link only: it does not collect, store, score or interpret LTB records.

3.4 Background Information

Results of background checks such as criminal record checks, court records search, and other screening databases or watch-lists as permitted by law.

3.5 Guarantor Information

If you provide a guarantor for your lease, we collect similar identity and financial information about that guarantor (with their consent), such as their name, contact details, identification, credit and income verification data, for the purpose of linking them to your Profile.

3.6 System and Usage Data

Technical information related to your use of the platform and Services. This includes device identifiers, IP addresses, cookie identifiers, browser type, operating system, access times, and activity logs. We collect this data to monitor system performance, maintain security (e.g. detecting fraud or unauthorized access), and improve user experience. Cookies and similar technologies may be used to remember your preferences and track usage analytics. You can change your cookie choices at any time by selecting Your Privacy Choices in the footer of any page. Our Cookie Policy lists the cookies we use and explains how to manage them.

TrueTenant collects and uses Personal Information for the following purposes, and will not use it for other purposes without your consent or as required/permitted by law:

a. Profile Creation and Reuse
To establish, maintain, and update your reusable tenant Profile, including calculating and updating your TrueTenant Score. This allows you to re-use your verified information for multiple rental applications without needing to re-submit data each time.

b. Tenant Screening Services
To provide tenant screening reports and Profile data to Landlords/Property Managers that you choose to apply or submit your Profile to, so they can evaluate your rental applications quickly and objectively.

c. Identity Verification and Fraud Prevention
To verify your identity (for example, through biometric matching of your ID photo) and to detect and prevent fraud, impersonation, or other unauthorized activities on the platform.

d. Lease and Property Management
To facilitate rental transactions and tenancy management, such as assisting with lease agreements, rent payment processing, maintenance requests, renewals, and other property management functions related to any tenancy you enter via our platform.

e. Service Improvement and Analytics
To improve and develop our Services. This includes using Personal Information (in identified or anonymized form) to train and refine TrueTenant’s AI-driven analytics and scoring algorithms, to conduct research and analytics about our user base and service usage, and to enhance user experience and security.

f. Alternative Housing Offers (With Consent)
With your explicit opt-in consent, to present you with or refer you to alternative rental housing options or related services in cases where you may not qualify for a specific property. This will only be done if you agree to such use of your Profile for finding other opportunities.

g. Communications and Customer Support
To communicate with you about your account and the Services. For example, we use your contact information to send account confirmations, application status updates, responses to your inquiries or support requests, and updates about new features or policy changes.

h. Legal Obligations and Enforcement
To comply with our legal and regulatory obligations (for instance, privacy laws, credit reporting rules, or court orders) and to enforce our agreements and defend our legal rights. This includes using or disclosing information as required to cooperate with regulators, to resolve disputes, or to address violations of law or our Terms of Service.

5.1 Mandatory Consent

Your consent to the collection, retention, and use of your Personal Information for creating and maintaining a reusable tenant Profile is a mandatory condition for using the Services. In other words, you cannot create or maintain a Profile without agreeing to this ongoing use of your information. We will only collect and use information that is necessary for the purposes outlined in this Policy and as allowed by law.

5.2 Profile Reuse

Once created, your Profile (and TrueTenant Score) can be re-used to apply for multiple rental properties without requiring you to undergo repeated screenings. This reuse is always subject to your ongoing consent. You control which Landlords/Property Managers can view your Profile when you choose to apply to their listings.

5.3 Withdrawal of Consent

You have the right to withdraw your consent at any time. You may do so by deactivating your Profile in your account settings or contacting us to request deletion. Upon withdrawal of consent, TrueTenant will delete your Profile and associated Personal Information, subject to the retention provisions in Section 6 below.

Please note that withdrawing consent will mean we can no longer provide you with the Services (since we cannot maintain your Profile). Any pending rental applications through TrueTenant may be cancelled if you withdraw consent before they are completed. TrueTenant will also inform any third parties who received your data (such as a prospective landlord) of your withdrawal if appropriate.

Note: In certain cases, Canadian law allows or requires us to collect, use, or retain personal information without consent (for example, to investigate fraud or as required by a subpoena). This Policy does not limit any such legal exceptions.

TrueTenant retains Personal Information only for as long as necessary to fulfill the purposes described in this Policy or as required by law. Our retention practices are as follows:

6.1 Retention of an Active Profile

To provide the core benefit of a reusable Profile, we retain your Personal Information for as long as you choose to maintain an active account with us. An account is considered active as long as you periodically log in. If an account has no login activity for a continuous period of thirty-six (36) months, it will be deemed inactive. Prior to taking any action, we will notify you via the email address on file, providing you with an opportunity to keep your account active.

6.2 Retention During and After an Active Tenancy

If a User’s rental application is successful and they become a tenant, we will retain the User’s Profile and related Personal Information for the duration of that tenancy and for up to two (2) years after the tenancy ends. This specific retention period is necessary for handling potential dispute resolution, providing landlord references, and meeting legal or regulatory requirements that may arise from the tenancy.

6.3 Anonymized Data

TrueTenant may retain data that has been anonymized or aggregated (i.e., it can no longer be associated with you personally) indefinitely. We use such anonymized data for statistical analysis, service improvements, and business planning and development.

6.4 Legal and Compliance Retention

Notwithstanding the above, TrueTenant may retain certain Personal Information for longer periods if required to comply with applicable laws, regulations, or legitimate business obligations. For example, we may need to keep records to resolve legal claims or comply with financial reporting laws.

6.5 Deletion and Disposal

Once Personal Information is no longer required for the purposes stated above, TrueTenant will permanently erase, delete, or anonymize the information in a secure manner. When you request the deletion of your Profile, we will delete all information not subject to a required legal or compliance retention period.

TrueTenant will disclose your Personal Information to third parties only in the following circumstances, and always in accordance with this Policy and applicable law:

a. To Landlords/Property Managers (User-Initiated)
We share your Profile information with a Landlord or Property Manager only when you choose to apply to a rental property or otherwise direct us to do so. TrueTenant contractually requires Landlords/Property Managers using our platform to handle your information in compliance with privacy laws and to refrain from harassment or any misuse of your data.

b. To Guarantors Authorized by You
If you designate a guarantor or co-signer in your Profile, we may share necessary information with that guarantor (and collect information from them) for the purpose of linking them to your application obligation. This occurs only with your involvement and the guarantor’s consent.

c. To Third-Party Service Providers
We disclose relevant Personal Information to trusted third-party service providers who perform services on our behalf. This includes credit bureaus (e.g. Equifax), financial aggregators (e.g. Flinks), identity verification services, payment processors, cloud storage or IT service providers, and background check agencies. These third parties are contractually obligated to protect your Personal Information and use it solely for the purposes we specify.

d. For Legal or Regulatory Compliance
We may disclose Personal Information to government, regulatory, or judicial authorities as required by law. We will also disclose information as necessary to protect the rights, property, or safety of TrueTenant, our users, or the public.

e. Business Transfers
If TrueTenant is involved in a business transaction such as a merger, acquisition, or sale of assets, Personal Information may be disclosed to the successors or assigns. We will ensure your Personal Information remains subject to confidentiality obligations and will provide notice before Personal Information is transferred.

f. Advertising and Referral Partners (With Consent)
TrueTenant may offer programs or partnerships that involve sharing your information with third parties for advertising, referral, or promotional purposes only if you provide explicit consent. You have the choice to participate in or decline any such program.

No Sale of Personal Information: We do not sell, rent, or disclose your Personal Information to third parties for their own marketing or commercial uses without your consent. TrueTenant’s disclosures are limited to the purposes listed above.

Subject to applicable laws, individuals using TrueTenant have the following rights regarding their Personal Information:

• ✓ Access Your Information: You have the right to access the Personal Information that TrueTenant holds about you. We will provide you with a copy or description, typically within 30 days.
• ✓ Corrections and Updates: If any of your Personal Information is inaccurate or incomplete, you have the right to request a correction or update.
• ✓ Deletion (“Right to be Forgotten”): You may request deletion of your Profile and associated Personal Information from TrueTenant’s systems.
• ✓ Withdraw Consent: You have the right to withdraw your consent to our continued use or retention of your Personal Information.
• ✓ Data Portability: You have the right to obtain a copy of your reusable tenant Profile in a portable, machine-readable format.
• ✓ File Complaints: You have the right to file a complaint with the Office of the Privacy Commissioner of Canada or your provincial privacy commissioner.

Exercising Your Rights: You can exercise many of the above rights directly through the TrueTenant platform. For any requests or questions, contact our Privacy Officer (see Section 16). TrueTenant will respond to legitimate requests within 30 days under PIPEDA.

TrueTenant takes the security of Personal Information very seriously and implements reasonable and appropriate technical, physical, and organizational safeguards to protect against unauthorized access, disclosure, or loss of your data. These measures include:

• Encryption: Strong encryption protocols protect Personal Information during transmission and storage.
• Identity Verification: Biometric identity verification and AI-driven fraud detection tools prevent unauthorized access.
• Access Controls: Strict access controls ensure only authorized personnel can access information on a need-to-know basis.
• Employee Training: All staff are trained on their responsibilities to protect Personal Information.
• Security Audits: Regular audits and tests identify and address potential vulnerabilities.

Note: Despite our robust safeguards, no method of transmission over the Internet is 100% secure. In the unlikely event of a security breach, we have put in place a response plan (see Section 10).

TrueTenant has implemented a Data Breach Response Plan. In the event of a breach involving loss, theft, or unauthorized access to Personal Information that poses a “real risk of significant harm” to any individual, TrueTenant will:

• Contain and investigate the breach;
• Assess the risk of harm;
• Notify the federal Privacy Commissioner of Canada (and any relevant provincial regulators) as soon as feasible;
• Notify all individuals whose information was involved and who may be at risk; and
• Keep a record of all data breaches as required by law.

TrueTenant is based in Canada, but the Personal Information we collect may be stored or processed on servers located outside of Canada, including in the United States. When we transfer or store Personal Information in another country, we will implement contractual and technical safeguards to ensure it receives a level of protection comparable to that provided under Canadian privacy laws.

Be aware that Personal Information stored outside Canada may be subject to the laws of that country and may be accessible to foreign courts, law enforcement and national security authorities in those jurisdictions.

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly solicit or collect Personal Information from minors. If we become aware that a person under 18 has provided us with Personal Information, we will take immediate steps to delete that information.

TrueTenant reserves the right to amend or update this Privacy Policy. If any changes are material, we will provide a prominent notice to Users, such as by email or an in-app alert. Your continued use of the Services after any updated Policy has become effective will signify your acceptance of the changes.

TrueTenant’s Personal Information handling practices are designed to meet or exceed the requirements of privacy laws across Canada.

14.1 Federal Law (PIPEDA): This Policy is governed by the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”). We uphold the ten Fair Information Principles of PIPEDA. TrueTenant has appointed a Privacy Officer responsible for overseeing our compliance.

14.2 Provincial Private-Sector Privacy Laws: In provinces with their own private-sector privacy laws (Alberta, British Columbia, and Québec), we also abide by those laws, ensuring compliance with any additional or stricter requirements.

14.3 Ontario Residential Tenancies Act Considerations: We handle Personal Information in a manner consistent with tenant protections from privacy intrusions and harassment under sections 22 and 23 of Ontario’s Residential Tenancies Act, 2006.

14.4 Other Provinces and Territories: In all other Canadian jurisdictions, our practices are intended to meet the requirements of PIPEDA.

14.5 Ongoing and Future Compliance: We are committed to remaining compliant with any new or amended privacy legislation.

14.6 International Expansion: If TrueTenant expands its Services beyond Canada, we will comply with all applicable data protection laws in those jurisdictions.

This Privacy Policy and any disputes arising from it shall be governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein.

If you have any questions, concerns, or requests regarding this Privacy Policy or how TrueTenant handles your Personal Information, please contact our designated Privacy Officer at support@truetenant.ai.

Privacy Officer
TrueTenant Inc.
713 Indian Road
Mississauga, Ontario L5H 1R3
Canada
Email: support@truetenant.ai