REita Privacy Notice

1. About REita

REita is REintel Technology Inc.’s AI SMS concierge that replies to client messages on behalf of real-estate partners. This notice covers the specific ways REita handles personal information, in addition to the general REintel Privacy Policy.

2. Territorial Scope

REita is currently available to real-estate partners whose registered operating jurisdiction is a Canadian province or territory excluding Québec. Partners licensed by the OACIQ are not onboarded at this time. If you are a Québec resident who has received a REita message from a non-Québec partner, the disclosures in sections 3–8 still apply to you, and you may contact our Privacy Officer at privacy@reintel.ca to exercise any right available under P-39.1.

3. Automated Decisions and Human Oversight

REita generates replies using a large language model based on the context of your conversation with the partner you contacted. In many cases, REita’s draft is sent without individual human review of that specific message. This means:

• An AI system may produce the message you receive from the partner’s number.
• The principal factors REita considers are: the content of your message, the partner’s configured guardrails, recent conversation history, and (where applicable) property details relevant to your inquiry.
• You may request human review of any automated message by replying HUMAN in the conversation, or by emailing privacy@reintel.ca.

4. Consent (CASL)

When REita replies directly to a message you initiated, that reply is a Transactional Reply and does not require your consent under CASL.

When REita sends commercial outreach on a partner’s behalf (e.g., property suggestions), the partner must have a valid consent record for you under one of CASL’s consent tracks:

• Inquiry-based implied consent — valid for 6 months from your qualifying inquiry (CASL §10(1)(a)(i)).
• Existing-business-relationship implied consent — valid for 24 months from a prior purchase or lease (CASL §10(1)(a)(ii)).
• Express consent — indefinite until you unsubscribe (CASL §10(6)).

You can revoke consent at any time by replying STOP to any message, or by emailing privacy@reintel.ca. REintel honours unsubscribe requests within 10 business days per CASL §11(3).

5. Sub-processors (Cross-Border Transfer)

REita depends on the following sub-processors. Some operate outside of Canada; REintel has executed Data Processing Addenda with each to ensure equivalent protections.

Anthropic uses its own sub-processors (cloud infrastructure providers and, as disclosed by Anthropic in March 2026, additional infrastructure including AWS GovCloud and Palantir). Anthropic’s current sub-processor list is maintained at trust.anthropic.com/subprocessors.

6. Retention

REita conversation content is retained based on the partner’s pricing tier: 6 months (Starter), 12 months (Professional), or up to 36 months (Enterprise, with an optional extension to a 7-year maximum under a specific written business purpose). CASL consent records are retained for 3 years from the last message or consent event, whichever is later. Security-incident records are retained for 24 months per PIPEDA §10.3.

7. Your Rights

You have the following rights under PIPEDA and (for Québec residents) P-39.1. To exercise any right, email privacy@reintel.ca.

• Access. Request a copy of your conversation records, consent records, and any audit scores attributable to you, in JSON or CSV format. We respond within 30 days (PIPEDA §8; access fees may apply under §8(5)).
• Correction. Request correction of inaccurate or incomplete information. We respond within 30 days.
• Erasure (Right to be Forgotten). Request deletion of all your conversation records, consent records, and contact-memory rows. We complete the cascade within 7 business days (and transmit deletion requests to applicable sub-processors within the same window).
• De-indexing. Request de-indexing of any publicly-accessible information involving you.
• Human Review. Request that a human review any automated message you received.
• Withdrawal of Consent. Revoke any consent you gave. Reply STOP to opt out of commercial messages instantly.

8. Security-Incident Notification

If a security incident involving your personal information creates a Real Risk of Significant Harm (PIPEDA §10.1(7)), we notify the Office of the Privacy Commissioner of Canada and you directly, as soon as feasible. For Québec residents, we also notify the Commission d’accès à l’information per P-39.1 §3.5.

9. Privacy Officer

REintel’s Privacy Officer is Jeff Chisholm, Principal, REintel Technology Inc. Contact: privacy@reintel.ca. If you are not satisfied with our response to a privacy concern, you may escalate to the Office of the Privacy Commissioner of Canada at priv.gc.ca.

10. Changes

We may update this notice to reflect changes in law, our sub-processors, or our practices. Material changes will be highlighted at the top of this page for at least 30 days.

Last updated: April 19, 2026. Addendum reference: v0.9.