Privacy Policy

1. Introduction

9533-1518 Québec Inc., doing business as Pilr Inc. (“Pilr”, “we”, “us”, “our”), operates le topo, a real estate due diligence tool offered as an online platform (the “Service”), and the le topo product website at https://letopo.ai (the “Site”). This Privacy Policy explains how we collect, use, disclose, and protect personal information in connection with the Service and the le topo Site.

We are committed to protecting personal information in accordance with the Act respecting the protection of personal information in the private sector (Quebec), as amended by Act 25, as well as applicable Canadian laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA).

This policy applies to the le topo product (the Service and the Site letopo.ai).

Our separate corporate website, at https://pilr.ai, is governed by its own privacy policy. By creating a le topo account, using the Service, or submitting information through the Site, you agree to the practices described in this policy.

2. Who is this policy addressed to?

le topo is a professional tool for real estate brokers, agencies, and other real estate professionals and businesses. In this policy, "you" refers to a user of the Service or a visitor to the Site.

3. Personal information we collect

a) Account and profile information.

When you register for and use the Service, we collect your first and last name, email address, phone number (if applicable), business information (such as your agency or brokerage firm, business or licensing information you choose to provide, and your company) and your account credentials.

b) Information that you submit or upload.

We collect the addresses and properties you search for, the documents, files, and content you upload to the platform (including property-related documents), as well as your communications, requests, and correspondence with us. The documents you upload may themselves contain personal information about other individuals (see section 4).

c) Payment information.

When you subscribe, payments are processed by our third-party payment service provider, Stripe. Stripe directly collects and processes your payment card and billing information. We do not receive or store full payment card numbers. We receive limited billing and transaction information, such as your name, billing email address, subscription status, the last digits of your card, and payment confirmations.

d) Information collected automatically.

When you use the Service or the Site, we and our infrastructure providers process standard technical data, such as your IP address, device and browser, the pages and features you use, as well as logging, diagnostic and security data, to operate, secure and improve the Service and the Site.

e) Witnesses and similar technologies.

See section 12.

4. Real estate data and information concerning third parties

le topo helps you gather and review property information from public, municipal, environmental, and third-party sources. Much of this information comes from public records and other publicly accessible sources. You can also upload documents containing personal information about other people (for example, owners named in public records).

It is your responsibility to ensure that you have the right to upload and process this information for your business purposes, and to use the resulting reports in accordance with applicable law and your professional obligations. We process this information on your behalf to provide you with the Service.

5. Purposes of collection and use

We collect and use personal information only for legitimate, specific, and necessary purposes, including:

• create, authenticate and manage your account;
• to provide, operate, maintain and improve the Service, including aggregating property information and generating reports;
• process your subscription and payments (via Stripe);
• communicate with you, respond to your requests and offer support;
• to ensure the security and integrity of the Service and to prevent fraud, abuse and misuse;
• to comply with our legal, regulatory and professional obligations.

6. Consent

We collect and use personal information with your consent, obtained in accordance with applicable law. We rely on express consent where required by law (for example, for account creation or sensitive information) and on implied consent where appropriate, depending on the context and your use of the Service.

You may withdraw your consent at any time by contacting our Privacy Officer (see section 15), subject to legal or contractual limitations. Withdrawing certain consents may prevent us from providing all or part of the Service.

7. Use and disclosure of information

Pilr does not sell any personal information.

We only share personal information with the following individuals and entities:

• our staff and our authorized agents who need access to it in order to operate the Service, and who are bound by confidentiality;
• service providers who process personal information on our behalf and according to our instructions, including Stripe (payment processing, in the United States) and providers who host, secure and store the Service and your data in Quebec, Canada;
• our professional advisors (for example, legal and accounting advisors); and
• governmental, regulatory or other authorities, when required or permitted by law, or when necessary to establish, exercise or defend our rights.

We require all third parties to maintain the confidentiality of personal information, to protect it through appropriate measures, and to use it only for the purposes we specify.

8. Conservation

We retain personal information only for as long as necessary to fulfill the purposes described in this policy, to provide the Service, and to comply with our legal, regulatory, accounting, and professional obligations. Account information is retained for the duration of your account and for a reasonable period thereafter. Documents you upload and generated reports are retained according to your account and our operational needs, after which they are deleted or anonymized. Server and security logs are retained for limited periods.

9. Security Measures

We implement reasonable physical, technical, and administrative security measures to protect personal information, including:

• encryption in transit (HTTPS/TLS);
• access controls, authentication and the principle of least privilege;
• hosting and storing the Service's data in Quebec, Canada, with appropriate technical and organizational measures;
• confidentiality agreements with our staff and suppliers; and
• monitoring and logging to detect and prevent abuse.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. It is your responsibility to keep your account credentials confidential.

10. Your rights (Quebec and Canada)

Subject to applicable law, you have the right to:

• to access the personal information we hold about you;
• to request the correction of inaccurate, incomplete or outdated information;
• to withdraw your consent;
• to request the deletion or anonymization of your information where permitted by law;
• to receive the computerized personal information you have provided to us, in a structured and commonly used technological format (portability), when required by law; and
• to obtain information on any automated processing of your personal information, if applicable.

How to exercise your rights.

To exercise any of these rights, contact our Privacy Officer at [email protected] (or at the address listed in section 15). We will respond within the time frame required by law (generally within 30 days under Act 25).

Complaints.

If you are dissatisfied with how we handle your personal information or your request, you can file a complaint with the Commission d'accès à l'information du Québec (CAI) at www.cai.gouv.qc.ca. You can also contact the Office of the Privacy Commissioner of Canada under PIPEDA.

11. Automated processing

le topo analyzes property data and generates structured reports and risk signals to support your professional review. le topo does not make decisions with legal effects concerning you, or that significantly affect you, based solely on the automated processing of your personal information; the professional user always exercises their own judgment. If a decision concerning an individual were made solely on the basis of automated processing, we would, upon request, provide the information and rights stipulated by Law 25.

12. Witnesses and similar technologies

We use cookies and similar technologies necessary for the operation and security of the Service and the Site, for example, to keep you logged in, maintain your session, and protect against abuse. We may also use limited functional and measurement technologies to understand and improve the use of the Service. We do not use cookies for advertising purposes. You can manage cookies in your browser settings; disabling certain cookies may impair the functionality of the Service.

13. Transfers outside Quebec

The personal information processed through the le topo Service and Website is stored and processed in Quebec, Canada. However, some limited information is processed outside of Quebec and Canada by specific providers — in particular, payment card and billing information processed by Stripe in the United States.

Before such transfers, Pilr assesses whether the information will receive adequate protection (privacy impact assessment required by Law 25) and relies on contractual and other measures.

14. Minors

le topo is a professional tool and is not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors.

15. Person responsible for the protection of personal information

The person responsible for the protection of personal information at Pilr is:

Sherif Abuelwafa, Head of Privacy Protection — Email: [email protected] — Mailing Address: Montreal, Quebec, Canada.

16. Amendments to this policy

We may amend this policy from time to time. If so, we will update the "Last Updated" date at the top of this page, and any significant changes will be posted there. The current version is always available on the le topo website (and in its English version).

17. Contact us

For any questions or requests regarding this policy or your personal information:

9533-1518 Québec inc. (doing business as Pilr Inc.) — Montreal, Quebec, Canada — Email: [email protected].