Privacy policy.

Article I -- Statement of Principles

HOMEH Inc. ("HOMEH") acknowledges its obligations under Canadian privacy law, including the Personal Information Protection and Electronic Documents Act ("PIPEDA"), and any applicable provincial statutes. HOMEH is committed to the lawful collection, retention, use, and disclosure of personal information ("Personal Information") in the course of providing real estate brokerage and agency services, property management, leasing, and related advisory functions.

The preservation of accuracy, confidentiality, and security of client information remains fundamental to HOMEH's mandate as a registered real estate brokerage.

Article II -- Scope and Application

This Privacy Policy applies to all persons interacting with HOMEH, including:

• • Sellers and buyers of real property;
• • Landlords and tenants;
• • Prospective clients, investors, and website visitors;
• • Real estate agents and brokers engaged by HOMEH; and
• • Employment or independent contractor applicants.

This Policy governs Personal Information collected by HOMEH through any medium, including its websites, mobile applications, electronic communications, telephone, or written correspondence.

Article III -- Consent

By accessing HOMEH's services, platforms, or professional brokerage offerings, individuals are deemed to consent to the collection, use, and disclosure of their Personal Information for the purposes identified herein, subject always to withdrawal of such consent in accordance with Section X.

Where an individual creates an account or submits a request to be contacted, they expressly consent to HOMEH communicating with them through any of the contact channels they provide — including email, telephone, text message (SMS), WhatsApp and similar messaging platforms, social media, and application push notifications — about their account, saved searches, listings, and HOMEH's real estate services, until they unsubscribe or withdraw that consent.

No information will be utilized for secondary purposes without either express consent or legal authorization.

Article IV -- Collection of Information

HOMEH collects only such information as is reasonably required for the following lawful purposes:

1. Identity Verification -- in accordance with FINTRAC regulations and applicable federal statutes. This may include:
   • o Full legal name, residential address, date of birth, and occupation;
   • o Government-issued identification particulars (type, jurisdiction, expiry date, and ID number);
   • o Credit bureau references, financial account numbers, and verification by two independent sources;
   • o Social Insurance Number where mandated by law (e.g., Income Tax Act, PCMLTFA).
2. Real Estate Transactions -- information relating to the marketing, sale, purchase, or lease of properties, including ownership details, search preferences, saved listings, and comparable property assessments.
3. Employment and Agent Applications -- resumes, prior employment history, references, licensing data, and other qualifications required to evaluate applicants.
4. Electronic and Website Interactions -- IP addresses, location data, browser and device details, website navigation history, cookies, crash reports, and metadata arising from communications conducted via HOMEH's platforms.

All information is held in strict confidence, subject to retention and destruction in accordance with HOMEH's internal records management policies. Aggregated or anonymized data, incapable of identifying an individual, may be used without restriction.

Article V -- Use of Information

Personal Information is used exclusively for purposes directly connected with HOMEH's business as a real estate brokerage, namely:

• • Marketing and advertising of real property;
• • Locating, assessing, and qualifying property opportunities for clients;
• • Preparation of agreements, disclosures, and transaction documentation;
• • Communication of updates, offers, and service notices;
• • Employment or independent contractor evaluations;
• • Customer service follow-up and quality assurance;
• • Personalization of client experience, including tailored search results;
• • Fraud detection, compliance, and prevention of misuse of HOMEH's services.

Article VI -- Disclosure of Information

Personal Information shall remain confidential and shall not be disclosed except in the following circumstances:

1. With Consent -- including disclosure to the Multiple Listing Service (MLS) systems, local real estate boards, the Canadian Real Estate Association, and transaction counterparties (e.g., cooperating brokerages, appraisers, lenders, inspectors, and solicitors).
2. As Required by Law -- where disclosure is mandated by statute, regulation, or a valid order of a court or tribunal.
3. As Permitted by Law -- in exceptional cases provided for under Canadian privacy legislation.
4. Corporate Transactions -- in connection with mergers, sales, insolvency proceedings, or similar corporate reorganizations, subject to strict confidentiality undertakings.

Article VII -- Safeguards and Security

HOMEH maintains robust physical, technical, and administrative controls to protect Personal Information, including:

• • Restricted access to client files and data systems;
• • Authentication procedures prior to granting file access;
• • Secure destruction of records once business purposes are fulfilled, except where retention is mandated by law.

Unauthorized use or disclosure by HOMEH agents, brokers, or employees constitutes a breach of professional duty and may result in disciplinary or contractual consequences.

Article VIII -- International Transfers

Personal Information may be processed or stored outside Canada. While such jurisdictions may have differing data protection standards, HOMEH shall ensure compliance with applicable Canadian legal obligations and shall exercise commercially reasonable efforts to safeguard transferred data.

Article IX -- Website, Cookies, and Location Data

HOMEH's online services utilize cookies and related technologies to enhance usability, measure effectiveness, and personalize client interactions. Browser configurations may be adjusted to limit or refuse cookies, although certain functionalities may be impaired.

If mobile or browser location services are enabled, HOMEH may use location data to provide geographically relevant search results and advertising.

Article X -- Rights of Access, Correction, and Withdrawal

1. Access and Correction -- Individuals may request access to, or correction of, their Personal Information by submitting a written request to the Chief Executive Officer. Proof of identity will be required. Access may be denied where legally permissible, with reasons provided in writing.
2. Withdrawal of Consent -- Consent to collection, use, or disclosure may be withdrawn upon reasonable notice, subject to legal and contractual restrictions. Withdrawal may impact HOMEH's ability to provide certain brokerage services.

Article XI -- Chat Feature

HOMEH provides a chat function for direct user-to-user communication. HOMEH does not monitor message content. Only minimal technical data (timestamps, routing data) is processed for delivery. Users bear sole responsibility for the content of their conversations.

Disclosure of chat logs will only occur if required by law or valid legal process.

Article XII -- European Residents

HOMEH operates solely in Canada & USA. Its services are not intended for, and are expressly prohibited to, residents of the European Union. Measures may be employed to restrict access by European IP addresses.

HOMEH does not knowingly collect information subject to the GDPR. Any European resident who circumvents these restrictions agrees to indemnify HOMEH for any resulting liability.

Article XIII -- Updates to this Policy

HOMEH may amend this Privacy Policy periodically. Notice of material amendments will be provided by way of publication of a revised version on HOMEH's website, together with an updated effective date. Clients are responsible for reviewing the most current version.

Article XIV -- Inquiries and Complaints

All questions, requests, or complaints relating to the handling of Personal Information should be directed to:

Privacy Officer

HOMEH Inc., Brokerage

505 Highway 7 East, Units 308 & 309, Thornhill, ON L3T 7T1

[email protected]