Privacy Policy

1. Introduction

Dedwell Inc. ("Dedwell," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our website, mobile applications, and related services (collectively, the "Platform").

This Privacy Policy is designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), the Privacy Act (federal), and applicable provincial privacy laws, including:

• Freedom of Information and Protection of Privacy Act (FIPPA) - British Columbia
• Act Respecting the Protection of Personal Information in the Private Sector (Law 25) - Quebec
• Personal Information Protection Act (PIPA) - Alberta
• Personal Information Protection Act (SNL2002) - Newfoundland and Labrador

By using our Platform, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.

2. Definitions

Personal Information means any information about an identifiable individual, including but not limited to:

• Name, address, email address, and contact information
• Date of birth and demographic information
• Financial and payment information
• IP addresses, device identifiers, and browsing history
• Images, photographs, and videos
• Employment and education history
• Immigration status and identification documents

Sensitive Personal Information includes personal information that reveals racial or ethnic origin, political opinions, religious beliefs, trade union membership, biometric information, health information, or financial information.

3. Information We Collect

3.1 Information You Provide Directly

We collect information you provide when you:

• Create an account: Name, email address, password, phone number, profile photo, and biographical information
• List a property: Property details, photos, address, rental terms, proof of ownership or management authority
• List marketplace items: Item descriptions, photos, pricing, and category information
• Request relocation services: Service preferences, travel dates, origin and destination information
• Complete your profile: Employment information, move-in dates, preferences, and interests
• Communicate with other users: Messages, reviews, and feedback
• Subscribe to newsletters: Email preferences and interests
• Contact support: Correspondence and any information you choose to share

3.2 Information Collected Automatically

When you access our Platform, we automatically collect:

• Device Information: Device type, operating system, browser type, and unique device identifiers
• Usage Data: Pages visited, features used, time spent on pages, and navigation patterns
• Location Data: General geographic location based on IP address or more precise location if you grant permission
• Log Data: Access times, referring URLs, and error logs
• Cookies and Similar Technologies: As described in our Cookie Policy

3.3 Information from Third Parties

We may receive information about you from third parties, including:

• Social media platforms (if you choose to link accounts)
• Verification service providers (for identity and address verification)
• Credit bureaus or background check services
• Public records and databases
• Marketing partners and analytics providers

4. How We Use Your Information

We use your personal information for the following purposes:

• Account Management: Creating and maintaining your account, verifying your identity, and providing customer support
• Platform Services: Facilitating property listings, marketplace transactions, and relocation services
• Communication: Sending you service-related notifications, updates, and promotional materials (with your consent)
• Personalization: Customizing your experience, recommending relevant properties and services
• Improvement: Analyzing usage patterns to improve our Platform, features, and services
• Security: Detecting and preventing fraud, unauthorized access, and other security incidents
• Legal Compliance: Complying with applicable laws, regulations, and legal processes
• Dispute Resolution: Resolving disputes between users and addressing complaints
• Verification: Conducting KYC (Know Your Customer) and verification checks on property owners

We will not use your personal information for purposes other than those stated without your consent, except as required by law.

5. Legal Basis for Processing (PIPEDA)

Under PIPEDA, we collect, use, and disclose personal information only with your consent, or as necessary to fulfill the purposes for which it was collected. We rely on the following legal bases:

• Consent: You have given clear consent to process your personal information for specific purposes
• Contractual Necessity: Processing is necessary to provide you with our services or fulfill our contractual obligations
• Legal Obligation: Processing is required to comply with applicable Canadian laws
• Legitimate Interests: Processing is necessary for our legitimate business interests (with appropriate safeguards)
• Vital Interests: Processing may be necessary to protect someone's life or physical safety

Quebec Residents (Law 25): For Quebec residents, we collect personal information only with your consent, except as permitted by law. You may withdraw your consent at any time, subject to legal or contractual restrictions.

6. Information Sharing and Disclosure

We may share your personal information with:

6.1 Other Users

• When you list a property, your name, profile photo, and listing details are visible to other users
• When you message another user, they can see your profile information
• Reviews and ratings may be associated with your account

6.2 Service Providers

We share information with trusted third-party service providers who assist us in:

• Payment processing (e.g., Stripe)
• Cloud hosting and data storage
• Email and push notification delivery
• Analytics and user research
• Identity verification and background checks
• Customer support and help desk services
• Marketing and advertising

These providers are contractually obligated to protect your information and use it only for the services they provide.

6.3 Legal Requirements

We may disclose your information when required by law, including:

• Compliance with valid legal processes (subpoenas, court orders)
• Response to lawful requests from government authorities
• Protection of our rights, privacy, safety, or property
• Prevention of fraud or illegal activity
• Enforcement of our Terms of Service

6.4 Business Transfers

If Dedwell is involved in a merger, acquisition, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you via email or prominent notice on our Platform before your information is transferred and becomes subject to a different Privacy Policy.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including:

• Providing you with our services
• Complying with legal obligations
• Resolving disputes and enforcing agreements
• Preventing fraud and abuse

Retention Periods:

• Account information: Retained while account is active, plus 2 years after closure
• Transaction records: Retained for 7 years (as required by Canadian tax law)
• Communication records: Retained for 3 years
• Marketing preferences: Retained until you withdraw consent
• Audit logs: Retained for 5 years

After these periods, your data will be securely deleted or anonymized, unless retention is required by law.

8. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security measures include:

• Encryption: Data in transit (TLS/SSL) and at rest (AES-256)
• Access Controls: Role-based access controls and least privilege principles
• Authentication: Multi-factor authentication for sensitive operations
• Monitoring: Continuous security monitoring and threat detection
• Regular Audits: Periodic security assessments and penetration testing
• Employee Training: Privacy and security awareness training
• Incident Response: Documented breach response procedures

While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

9. Your Rights Under PIPEDA

Under PIPEDA, you have the following rights regarding your personal information:

• Right to Access: Request access to your personal information and how it is being used
• Right to Correct: Request correction of inaccurate or incomplete information
• Right to Withdraw Consent: Withdraw consent for the collection, use, or disclosure of your information (subject to legal or contractual restrictions)
• Right to Delete: Request deletion of your personal information (subject to legal retention requirements)
• Right to Data Portability: Receive your information in a structured, commonly used format
• Right to Know: Know about third parties with whom your information has been shared
• Right to Challenge: Challenge our compliance with PIPEDA principles

To exercise these rights: Contact our Privacy Officer at privacy@dedwell.com. We will respond to your request within 30 days.

10. Additional Rights for Quebec Residents

Under Quebec's Act Respecting the Protection of Personal Information in the Private Sector (Law 25), Quebec residents have additional rights:

• Right to De-index: Request the removal of hyperlinks to your personal information that provides access to information revealing your identity
• Right to be Informed: Request information about third parties with whom personal information has been shared
• Privacy Officer: Designate a person responsible for protecting personal information

You may exercise these rights by contacting our Privacy Officer. We will respond within 30 days of receiving your request.

11. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and use information about you. For detailed information about the cookies we use, please see our Cookie Policy.

You can manage your cookie preferences through our cookie consent tool or your browser settings. Note that disabling certain cookies may affect the functionality of our Platform.

12. Children's Privacy

Our Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at privacy@dedwell.com.

If we become aware that we have collected personal information from a child under 18 without verified parental consent, we will take steps to delete that information promptly.

13. International Data Transfers

Your personal information may be transferred to and processed in countries other than Canada. When we transfer your information outside Canada, we ensure appropriate safeguards are in place, including:

• Verifying the destination country has adequate data protection laws
• Using contractual protections (e.g., Standard Contractual Clauses)
• Ensuring compliance with PIPEDA requirements for cross-border transfers

By using our Platform, you consent to such transfers of your information.

14. Automated Decision-Making

We may use automated systems to make decisions in certain circumstances, including:

• Fraud detection and prevention
• Content moderation
• Risk assessment for property owners
• Personalized recommendations

You have the right to:

• Request human intervention in automated decisions
• Express your point of view
• Contest the decision

To exercise these rights, please contact our Privacy Officer.

15. Data Breach Notification

In accordance with PIPEDA and provincial privacy laws, we will notify you and the appropriate privacy commissioner if we become aware of a data breach that creates a real risk of significant harm to you. Notification will include:

• Description of the breach and circumstances
• Categories of affected individuals and information
• Steps we are taking to address the breach
• Recommendations for protecting yourself

We will make reasonable efforts to notify affected individuals as soon as possible, and no later than:

• Federal requirement: As soon as feasible
• Quebec (Law 25): Within 72 hours of becoming aware
• Alberta (PIPA): Without unreasonable delay

16. Third-Party Links and Services

Our Platform may contain links to third-party websites, services, or applications not controlled by Dedwell. This Privacy Policy does not apply to third-party services. We encourage you to review the privacy policies of any third-party services you access.

Examples of third-party services include:

• Social media platforms
• Payment processors (e.g., Stripe)
• External verification services
• Analytics providers

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes by:

• Posting the updated Privacy Policy on our Platform with a revised "Last updated" date
• Sending an email notification to the address associated with your account
• Displaying a notice within the Platform for 30 days

Your continued use of our Platform after such changes constitutes your acceptance of the revised Privacy Policy.

18. Contact Information and Complaints

If you have questions, concerns, or complaints about this Privacy Policy or our privacy practices, please contact us:

Filing a Complaint with the Privacy Commissioner

If you are not satisfied with our response, you may file a complaint with the appropriate privacy commissioner:

• Federal (PIPEDA): Office of the Privacy Commissioner of Canada - www.priv.gc.ca
• British Columbia: Office of the Information and Privacy Commissioner - www.oipc.bc.ca
• Alberta: Office of the Information and Privacy Commissioner - www.oipc.ab.ca
• Quebec: Commission d'accès à l'information - www.cai.gouv.qc.ca
• Ontario: Information and Privacy Commissioner of Ontario - www.ipc.on.ca