Modsave Inc., doing business as RealEstateContent.ai (“RealEstateContent”, “we”, “us”, “our”), owns and operates the website at realestatecontent.ai (“Website”) and the RealEstateContent service, an AI-powered marketing platform for real estate professionals that allows Users to generate, customize, manage, and publish marketing content, including content based on User-provided profile information, real estate listing information, and optional digital likeness or voice features (“Platform” and together with Website, “Service”).

This privacy policy (“Privacy Policy”) describes how we collect, store, use, and distribute your information, including personally identifiable information about an individual (“Personal Information”), via the Service. The policies contained herein are designed to comply with both Federal Trade Commission (“FTC”) and Consumer Financial Protection Bureau (“CFPB”) requirements, as well as the regulations relative to data collection and sharing contained in the Gramm-Leach-Bliley Act (“GLBA”), as applicable. Please read the following carefully to understand our practices regarding Personal Information about users who access and browse the Website and Personal Information about or shared with us by RealEstateContent customers (“Customers”) who use the Service, all collectively referred to as “Users”, “you”, or “your”).

We may change this Privacy Policy from time to time at our sole discretion. We encourage you to review this Privacy Policy each time you use the Service to see if the Privacy Policy has been changed, as indicated by the “Last Updated” date set out above. We may require you to provide consent to the updated Privacy Policy before further use of the Service is permitted.

The Service is intended for use in Canada and the United States and is not directed to residents of the European Economic Area, the United Kingdom, or Switzerland. This Privacy Policy is not designed to satisfy the requirements of the General Data Protection Regulation, the UK GDPR, or Swiss privacy laws.

1. Privacy Practices of Customers. As part of using the Platform, Customers may make Personal Information about third parties available to us. Customers warrant that any third party information provided to us will be in compliance with FTC and CFPB regulations and allowably transmitted pursuant to the GLBA. Note the GLBA prohibits the transmission of Non-Public Personal Information (“NPI”) about third parties to another without proper consent. This Privacy Policy does not apply to the collection, use, and disclosure of Personal Information by Customers for their own purposes. If you want information about whether the Platform is used by an organization that is one of our Customers, the purposes for which your Personal Information is being collected, used or disclosed by the Customer or the Customer’s privacy practices, we encourage you to contact the Customer directly. Customers are responsible for ensuring that they have all rights, notices, consents, and lawful bases necessary to provide us with Personal Information or other information about third parties, including information contained in real estate listings, public profiles, marketing materials, or other content submitted to or accessed through the Service.
2. Consent.By using the Service, you acknowledge that we may collect, use, and disclose your Personal Information as described in this Privacy Policy. Except as set forth in this Privacy Policy, your Personal Information will not be collected, stored, used, or disclosed for any other purpose without your consent. We will not actively collect Personal Information for the purpose of sale or marketing of such Personal Information in a way that specifically identifies an individual. Subject to applicable law, you may request deletion of your Personal Information or opt out of certain processing as described in this Privacy Policy. However, withdrawing consent may result in your inability to continue using all or part of the Service.
3. Information You Provide to Us.We may collect Personal Information you disclose to us as follows:

1. Contacting us via the Website. Certain functionality of the Website may enable you to contact us, in which case we collect any Personal Information you may choose to provide to us via the Website. We ask that you do not disclose any sensitive Personal Information when you contact us. 
2. Platform Registration and Use. If you wish to become a Customer, we collect information required to onboard you onto the Platform such as your name, email address, and billing information. During the Platform account creation and onboarding process, we collect any Personal Information you choose to provide us to build your user profile, configure your account, generate marketing content, or personalize the Service. Once you are onboarded onto the Platform, we collect any Personal Information you share with us while using the Platform, such as Personal Information contained in prompts, profile information, listing information, images, audio recordings, voice samples, or other inputs you provide to use the content generation, profile enrichment, listings, or optional AI Twin features of the Platform. We ask that you do not disclose sensitive Personal Information when you use the Platform.
3. Third-Party Integrations. We may integrate with or rely on third-party platforms and services to provide the Service to you (“Third-Party Integrations”). For example, we allow you to sync your social networking accounts, such as Instagram, Meta, X, or LinkedIn, with the Platform via API. Any Personal Information submitted to us via Third-Party Integrations that we can access will be subject to this Privacy Policy, but please note that such Personal Information will also be subject to the terms of the applicable Third-Party Integration.
4. Applying to Work with Us. If you would like to work with us and submit hiring materials to us (either directly or though a Third-Party Service or recruiter), we collect any Personal Information in your hiring materials, such as your resume, cover letter, transcripts, or certifications. If you submit hiring materials to us, we ask you to only include information relevant to your job application. Please note that any Personal Information you submit through a Third-Party Integration or recruiter will be subject to the privacy practices of those entities. If you are a current RealEstateContent employee, please contact our Privacy Officer per Section 12 below for more information on how your employee information may be collected, stored, used, and distributed.
5. AI Twin Features. If you choose to use any optional feature that generates or uses a digital likeness, voice clone, synthetic voice, avatar, or similar representation of you (“AI Twin”), we may collect images, video, audio recordings, voice samples, likeness information, and related information you provide to create, operate, support, and improve that feature. Some of this information may be considered biometric information, biometric identifiers, biometric data, or sensitive Personal Information under applicable law. We will only collect and use this information where you choose to use the AI Twin feature and provide any required consent. You should not submit any image, voice, likeness, or biometric information of another person unless you have all rights and consents required to do so.

4. Information We Collect When You Use the Service.

1. Cookies. When you use the Service, RealEstateContent may collect certain information through technologies such as cookies and other automatic data collection technologies (“Cookies”). We may use Cookies for authentication and to compile aggregate statistics about usage of the Service, such as how long Users spend using the Service, and what parts or pages of the Website are viewed most often. This information is used to improve the content and operation of the Service. We may also use Cookies to promote the Service through marketing and advertising. These Cookies may be accessed or disclosed to third parties for the purpose of serving you relevant advertisements. You may opt out of Cookies or prevent third-party websites from accessing our Cookies by adjusting your privacy settings on your browser. We may use cookies and similar technologies for analytics and advertising purposes, including to personalize content and advertisements. Where required by applicable law, you may opt out of targeted advertising and certain cookie-based tracking by using our cookie settings tool, if available, or contacting us as described below. However, opting out of Cookies may disable some features of the Service and may prevent us from providing you with the information and services you have requested.
2. Device and Location Information. When you use the Service, RealEstateContent may collect information about your device (“Device Information”). Some Device Information, such as unique device identifiers, may constitute Personal Information. The Personal Information we collect from Device Information can depend on the individual settings of your device or browser that you use to access the Service. We recommend checking the policies of your device manufacturer or the browser’s provider to learn what Device Information may be shared with RealEstateContent. You may disable the sharing of Device Information, but doing so may disable some features of the Service and may prevent us from providing you with the information and services you have requested.
3. Public Profile and Listing Information. As part of onboarding and providing the Service, we may collect or retrieve publicly available information about you, your business, your professional profile, your social media accounts, your public website, and real estate listings associated with you or your business. This information may come from public websites, listing platforms, social media platforms, search results, or other publicly available sources. You may be asked to review and confirm certain sources or information before they are used in the Service.

5. How We Use Information We Collect.We use Personal Information in the following ways:

1. To authenticate and onboard you, and provide you access to the Service;
2. To provide, maintain, improve, and enhance the Service;
3. To personalize, configure, and improve content generated through the Service, including by using profile information, business information, listing information, and other inputs you provide or approve;
4. To provide optional AI Twin functionality, including generating or using a digital likeness, synthetic voice, avatar, or similar content where you have chosen to use that feature and provided any required consent;
5. To allow us and our affiliates to develop new products, features, and services;
6. To communicate with you, provide you with updates and other information relating to the Service, provide information that you request, respond to comments and questions, and otherwise provide customer support;
7. For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you, where you have subscribed to receive them;
8. To find and prevent fraud, and respond to trust and safety issues that may arise;
9. For compliance purposes, as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
10. For other purposes for which we provide notice at the time the Personal Information is collected. We do not use biometric information collected for AI Twin features to train artificial intelligence models.

6. Who We Share Your Information With.We may disclose Personal Information to our employees, contractors, affiliates, service providers, and other vendors that assist us in operating, providing, securing, supporting, analyzing, and improving the Service. These third parties may include providers that support hosting and infrastructure, artificial intelligence functionality, content generation, profile discovery and enrichment, public-source data collection, payment processing, customer support, analytics, advertising measurement, security, and social media integrations.

We have put in place contractual and other organizational safeguards with such third parties to protect your Personal Information from unauthorized uses and disclosures. Such third parties have limited access to Personal Information solely for the purposes described herein, and they will be subject to contractual restrictions prohibiting them from using such Personal Information for any other purpose.

Where we disclose Personal Information to third-party service providers, we do so for the limited purposes described in this Privacy Policy and subject to contractual or other safeguards designed to restrict their use of Personal Information to the services they provide to us.

In addition, we may disclose your Personal Information to third parties:

1. In connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets or shares, including any due diligence exercise carried out in relation to the same, provided that the Personal Information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the Personal Information;
2. If we have reason to believe that disclosing this Personal Information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities; or
3. If we believe in good faith that such disclosure is required by and in accordance with the law.

Our servers and those of third parties who may receive your Personal Information may be located outside of Canada and/or the U.S.. Accordingly, your Personal Information may be available to foreign governments or their agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.

7. Third Parties.The Service may contain links to third-party websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to the collection, storage, use, and disclosure of your Personal Information by such third parties.
8. Data Retention and Deletion.We retain Personal Information for as long as reasonably necessary to provide the Service, comply with our legal obligations, resolve disputes, enforce our agreements, and protect our business interests. All retained Personal Information will remain subject to the terms of this Privacy Policy. You have the right to ask us to remove your Personal Information from our databases, and we will do so to the best of our ability, but it may not be possible to completely delete all of your Personal Information due to technological and legal constraints (for example, when your Personal Information pertains to another User). For Personal Information associated with optional AI Twin features, including images, audio recordings, voice samples, likeness information, and any biometric information, we retain such information only for as long as reasonably necessary to provide the AI Twin feature, comply with applicable law, resolve disputes, enforce our agreements, or protect our business interests. If you delete your AI Twin, withdraw consent where applicable, or request deletion of associated information, we will delete or de-identify the applicable information as required by law and will take commercially reasonable steps to request deletion by service providers that processed the information on our behalf.
9. Your Privacy Rights; Access and Accuracy.Depending on where you live, you may have the right to request access to, correction of, deletion of, or a copy of your Personal Information; to opt out of certain processing activities, such as targeted advertising, the sale of Personal Information, or the sharing of Personal Information for cross-context behavioral advertising; to limit certain uses or disclosures of sensitive Personal Information; and to withdraw consent for certain optional features. To submit a request, please contact us using the information below. You may also access the Personal Information we hold about you to verify its accuracy, obtain a general account of our uses of your Personal Information, and request corrections as appropriate. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances we may not be able to make all relevant Personal Information available to you (for example, where that Personal Information also pertains to another User). In such circumstances, we will provide reasons for the denial to you upon request. We will make every reasonable effort to keep your Personal Information accurate and to respond to you in a timely manner. If you withdraw consent for an optional feature, including an AI Twin feature, we may be unable to continue providing that feature.
10. State-Specific Privacy Disclosures.This Section applies only to residents of jurisdictions whose privacy or biometric privacy laws provide the rights described below and supplements the rest of this Privacy Policy. Rights may vary depending on where you live, the nature of your relationship with us, and whether a particular law applies to us or to the relevant Personal Information.

California Privacy Rights. If you are a California resident, and to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to us and your Personal Information, you may have the right to know the categories of Personal Information we collect, use, disclose, sell, or share; to request access to or a copy of Personal Information; to request correction or deletion of Personal Information; to opt out of the sale or sharing of Personal Information; to limit certain uses or disclosures of sensitive Personal Information; and to be free from unlawful discrimination for exercising your privacy rights. We do not sell Personal Information for money, but certain cookies, advertising, analytics, or similar technologies may be considered a sale or sharing of Personal Information under some laws. Where required, you may exercise applicable opt-out rights by using available cookie settings or by contacting us as described below. We use sensitive Personal Information only to provide, secure, support, personalize, and improve the Service, with your consent where required, or as otherwise permitted by applicable law.

Illinois Biometric Information Notice. If you choose to use an optional AI Twin feature, we may collect, use, store, and disclose images, voice recordings, voice samples, likeness information, or related information that may be considered biometric identifiers, biometric information, biometric data, or sensitive Personal Information under applicable law. We collect and use this information solely to provide, operate, secure, support, and improve the AI Twin feature and related Service functionality, and not to identify you outside the Service or for unrelated purposes. We do not sell, lease, trade, or otherwise profit from biometric identifiers or biometric information. We may disclose such information only to service providers acting on our behalf, with your consent, as required by law, or as otherwise permitted by applicable law. We will retain biometric identifiers and biometric information until the initial purpose for collection has been satisfied or within three (3) years after your last interaction with us, whichever occurs first, unless a shorter retention period is required by applicable law. When the applicable retention period expires, consent is withdrawn, the AI Twin feature is deleted, or deletion is otherwise required by applicable law, we will delete or permanently de-identify the applicable biometric information in accordance with our retention practices and applicable legal requirements.

11. Security.We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff and third parties as reasonably necessary to carry out the stated purposes we have communicated to you.
12. Contact Us.If you want to enforce any of your rights under this Privacy Policy or if you have any questions regarding this Privacy Policy or your Personal Information, please contact our Privacy Officer per the information below:

1. Via email: Email us at support@realestatecontent.ai using the subject line “Re Privacy Policy”.
2. Via mail: Mail us correspondence to 151 Charles Street W, Kitchener, ON, N2G 1H6.