Effective Date: December 26, 2024

1. Introduction and Scope

This Privacy Policy (the “Policy”) outlines the practices of TenantPay Inc. (hereinafter referred to as “TenantPay", “ we”, “our”, or "us ”) regarding the processing of your personal information, as defined in the Definition of “personal information” section below. Specifically, the purpose of this Policy is to explain how and for what purposes TenantPay collects, uses, shares or otherwise processes personal information and how we safeguard the confidentiality of personal information when individuals visit our Website located at https://www.tenantpay.com/ (“Website”), when tenants add us as their rent payee on their online banking accounts to pay their rent, when tenants or landlords create a TenantPay account on our rent processing platform (the “ Platform”), or when individuals otherwise interact with us.

2. Definition of “personal information”

In this Policy, “personal information” means any information that can be used, either alone or in combination with other information, to identify an individual. This includes information such as your name, mailing address, e-mail address, telephone number, or any other contact details. It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is anonymized and cannot be associated with an identifiable individual is not considered to be personal information, if it is, reasonably foreseeable in the circumstances that this information irreversibly no longer allows you to be identified directly or indirectly.

3. Personal Information We Collect

The personal information we collect about you depends on the nature of your interactions with TenantPay (e.g., if you are a tenant or a landlord, if create an account on our Platform, etc.). Below is a description of the personal information we may collect about you.

a. Information we collect about tenants:

• Contact information you provide when creating an account on our Platform or when you send rent payment to TenantPay through online banking. This information may include your name, email address, and phone number. We may also receive your contact information from your landlord.

• Lease information you provide when creating an account on our Platform, such as property address, start and end date of your lease, due date of your lease, and lease document.

• Demographic information you provide when creating an account on our Platform. This information may include your area of employment.
  
• Financial information you provide when you use our Platform or when you send rent payments to TenantPay through online banking. This information may include your bank account details (e.g., account number) and details about the rent payments you send to TenantPay (payment methods, payments history, etc.).
• Other information you provide when creating an account on our Platform and which is  necessary for TenantPay to comply with our regulatory Know Your Customer (KYC) obligations.
  This information may include a copy of government-issued identification and your date of birth

 b. Information we collect about landlords:

• Building details you provide when creating an account on our Platform. This information may  include the address of properties you own and manage through our Platform and the rent  charged and lease duration for each. We may also collect any other information included in the  lease agreement you can upload when adding a new property to your account on our Platform
• Contact information you provide when creating an account on our Platform. This information may include your name, email, and phone number.
• Banking information you provide when you use our Platform. This information may include your bank account details (e.g., account number), payment methods, and the payment history of rent received from tenants.
• Other information you provide when creating an account on our Platform and which is  necessary for TenantPay to comply with our regulatory Know Your Customer (KYC) obligations.
  This information may include a copy of government-issued identification, your date of birth,  shareholding documents, record of existence, directors’ registry, and related documents

c. Information we collect about landlords and tenants from third parties:

We may collect information from third-party ID verification service providers to ensure that the  government-issued identification documents you provide us when creating an account on our Platform  are authentic, valid, and issued by recognized authorities. Our collection of such information helps us  comply with our regulatory Know Your Customer (KYC) obligations

d. Information we collect about visitors of our Website:

• Contact information, including your name, email, whether you are a landlord or tenant, and any other information you may provide us when using our Contact Form

• Information we collect automatically when you visit our Website using technologies such as cookies and pixels. The technical information we collect when you visit our Website includes . See the Cookies section below for more information on how we use cookies to collect your personal information.

4. How We Use Your Personal Information

We may use your personal information for general business purposes such as providing or delivering our services and Platform, managing our Website, preventing or reducing commercial risk, as well as for purposes relating to our information system or network security. More specifically, we may use your personal information for the following general business purposes:

• Managing our Website. We may use your personal information to manage and facilitate the use of our Website when you visit or access it, which may include using cookies and other similar technologies. See the Cookies section below for more information on how we use cookies.
• Providing or delivering our services.We may use your personal information to administer our Website or Platform, which may include transferring rent payments made to TenantPay as a payee to the appropriate landlords and notifying landlords of payments made by tenants.
  
• Book a Demo: If you contact us to request a demo of our Platform, we will use your contact information, and any other information you choose to provide to us for the purpose of contacting you to facilitate your request and discuss how our Platform can serve your needs.
  
• Communicating with you: If you contact us with a question or inquiry, we may use your personal information to respond to you. We may also send you updates, newsletters, offers, and promotions or other marketing communications using your email address or phone number. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt out of receiving marketing communications by contacting us using the contact information provided in the Contact Us section below. Please note that you may continue to receive transactional or account-related communications from us.
  
• For other purposes permitted or required by law. We may use personal information without your consent where we are legally permitted or required to do so by law, for example, to comply with a legal obligation or to protect the rights of TenantPay or to enforce or apply our terms of use and other agreements, or to detect, prevent and investigate suspicious, unauthorized, fraudulent, illegal or unlawful activity.

5. Sharing of Personal Information

We do not share your personal information to third parties without your consent, except as set forth below or as required or permitted by applicable law.

• Service providers. We may transfer or otherwise make available your personal information to  third parties that provide services on our behalf. We use service providers to provide services
  such as IT support, hosting the Website, storing data, providing marketing assistance,  conducting analytics, ID and credit verifications, processing credit card payments and providing  customer services.

• Credit reporting agencies. If you create a tenant account on our Platform we may share, , your rent payment history information with our partner credit reporting agencies. The sharing of such information is necessary for our partners to monitor your payment practices and adjust the pool of information that may use to perform credit verifications accordingly.
• Legal and compliance. We may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing, or preventing fraud, or as otherwise may be required or permitted by applicable Canadian or other law or legal process. Your personal information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
• Business transactions. We may disclose personal information to facilitate or enable any  corporate or commercial transaction involving TenantPay to the extent permitted by applicable  law.

Note that within TenantPay, our employees may have access, in whole or in part, to your personal information on a need-to-know basis.

6. Cross-border Transfers

Some of our external third-party service providers are based outside of Québec and/or Canada,  including in the United States. Their processing of your personal information will therefore involve a  transfer of information outside of Québec and/or Canada. Organizations based outside of Canada may  not be subject to privacy laws that provide you with the same rights and protections as in Canada. As a  result, when your personal information is used or stored in a jurisdiction other than where you are  residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or  requiring disclosure of the information to the government, government agencies, courts and law  enforcement in that jurisdiction.

7.Your Privacy Rights

Under privacy laws applicable in the region in which you reside, you may have the following rights with respect to your personal information, subject to limited exceptions set out in such laws:

• Right to information: You have the right to ask us about our processing of your personal information, including about the categories of persons who have access to your personal information within TenantPay and the applicable retention period.
• Right to access. You can ask us if we hold any personal information about you, and if so, you can request access to that personal information.

• Right to correction. You have the right to ask us to rectify any personal information that you demonstrate to be incorrect or outdated and to complete any information that you demonstrate to be incomplete.

• Right to withdraw consent. You may withdraw your consent to our processing of your personal information to the extent permitted by law and our contractual obligations. However, you understand that in such a case, you may no longer be able to benefit from our products and services.

To exercise any of your privacy rights, please contact us using the information provided in the Contact Us section below. Note that we may request certain personal information for the purpose of verifying the identity of the individual seeking to exercise their privacy rights.

8. Third Party Links

Our Website may contain links to other websites that TenantPay does not own or operate. We provide links to third-party websites as a convenience to the visitors of our Website. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

9. Cookies

We use cookies, web beacons (including pixels and tags), and similar technologies on our Website that collect certain information about you by automated means.

A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website’s features.

We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link:

• Google Analytics Browser Add-on

You can also obtain additional information on Google Analytics’ data privacy and security at the following links:

• Google Policies for Partner Sites
• Google Analytics Support - Privacy and Security

10. Minors

The Website is designed for a general audience and are not directed to children under the  We do not knowingly collect or solicit personal information from children under the age of 16 through the Website. If we become aware that we have collected personal information from a child under the age of 16 through the Website, we will promptly delete the information from our records. If you believe that a child under the age of 16 may have provided us with personal information, contact us as specified in the Contact Us section.

11. Retention

We will retain your personal information for as long as necessary to fulfill the purposes for which the information was collected. However, we may retain your personal information for a longer period when required to comply with our legal and regulatory obligations regarding information or record retention.

12. Security Safeguards

We protect and safeguard your personal information using physical, electronic and procedural measures appropriate to the volume and sensitivity of the information, the purposes for which it is used, and the format in which it is stored, including safeguards to protect your information against loss and theft, as well as unauthorized access, disclosure, copying, use, or modification. Specifically, we implement the following measures to protect your personal information, including:

• Internal policies and procedures that define the roles and responsibilities of our employees, representatives, and service providers throughout the life cycle of an item of information and limit their access to that information on a “need-to-know” basis;
• Physical, electronic and procedural safeguards that comply with relevant standards to protect personal information;
• If the information is collected or stored electronically, technical safeguards such as encryption, firewalls, passwords, anti-virus software and similar measures;
• A designated privacy officer to monitor TenantPay’s compliance with applicable privacy laws;
• Procedures for receiving, investigating, and responding to complaints or inquiries about TenantPay’s information handling practices; and
• Contractual protections to ensure that service providers with whom we share personal information maintain adequate protections and security standards.

If you have reason to believe that personal information has been compromised or accessed, used or disclosure unlawfully, please contact us using the information provided in the Contact Us section.

13. Updates to this Policy

This Policy is current as of the Effective Date set forth above and may be amended from time to time at our sole discretion. We recommend that you periodically review this Policy as it may be updated or revised from time to time. If we make material changes, we will take reasonable steps to notify you of those changes, including by posting the revised Policy on our Website with an adequate notice.

14. Contact Us

If you have any questions regarding our processing of your personal information or about this Policy, please contact our Privacy Officer in writing at support@tenantpay.com