Privacy Policy
Version 1.1
This Privacy Statement reflects the privacy practices of 1000101537 Ontario Inc. (“PropPay LX”, “we”, “us” or “our”) and describes how we process personal information provided to us as a processor for organizations who have purchased a license to our software and application known as “PropPay LX” (our “Customers”). Our Customers are organizations such as real estate developers who use our application to process personal information about purchasers of preconstruction real estate properties, including collecting and processing payments and deposits. As a service provider, we collect, use, disclose, store and process your personal information only as instructed by our Customers.
What personal information do we collect?
In this Privacy Statement, “personal information” includes any information about an identifiable individual or any information that may reasonably be linked to an individual.
We receive personal information from our Customers in order to help facilitate certain elements of a real estate transaction. For example, we may process the following personal information on behalf of our Customers:
- Details about the purchaser and / or the payor, including, name, mailing address, telephone number, email address;
- Banking information of the payor, such as bank account details; and
- Signatures.
How we may use your personal information
We act as a service provider or processor for our Customers. Accordingly, we process your personal information only as instructed by our Customers. Some of these purposes may include storing your personal information in our application and initiating the processing of payments and deposits on behalf of our Customers. We may use your banking information in order to collect payment for your use of PropPay LX. We may also use your phone number or email address to facilitate your access to the PropPay LX platform so that you view documents or other information.
How we may share your personal information
We will share your personal information to our Customers and to other third parties when instructed to by our Customers. These third parties may include lawyers and banks who are involved in processing your real estate transaction.
We will also share your personal information with:
- Third-party providers offering services such as hosting, data analytics, event logging, information technology;
- Third-party providers and suppliers assisting us in processing payments and deposits;
- A buyer or a successor in the event of a merger, restructuring, or other sale or transfer of some or all of our assets; or
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law, or when we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others.
How we protect your personal information?
We use reasonable and appropriate security measures designed to help secure your personal information against unauthorized use, loss, access, modification, destruction or disclosure while it is in our custody. These measures include physical, organizational and technological measures that are proportionate to the quantity and sensitivity of the personal information. Physical measures include secure work areas, and technological measures include encryption, firewalls, anti-virus and system security monitoring. Organizational measures include the use of access controls to restrict access to personal information on a “need to know” basis for our employees, contractors and agents.
Location and retention of your personal information
When authorized by our Customers, the personal information we collect is stored and processed on servers located in Canada.
The time periods for which we retain your personal information depend on the purposes for which we collected it. We routinely destroy personal information that is no longer required for the purpose for which it was collected, including for the purposes of processing the service ordered, or meeting any legal or reporting requirements.
Contact us
As a client of our Customer, please reach out to that Customer for more information regarding the collection and processing of your personal information. If you have any questions or comments about this Privacy Statement or the ways in which we process your personal information through the application, please contact us by email at privacy@proppaylx.app.
Updates
We may make changes to this Privacy Statement to reflect our current processing of your personal information. If we change the way we handle your personal information, we will update this Privacy Statement and notify you or seek your consent as and when appropriate.
Third-Party Data Processors
When you submit a registration or contact form on this website, your information may be shared with the following third-party service providers who process data on our behalf. Each provider is bound by its own privacy and data protection obligations.
| Service | Purpose | Data Shared | Privacy Policy |
|---|---|---|---|
| Plinthra CRM (plinthra.salefish.app) | Lead management and sales pipeline tracking | Name, email, phone, company, source page, device type, approximate location (city/region/country) | SaleFish Privacy Policy |
| ActiveCampaign | Email marketing and contact management | Name, email, phone, company, registration source | ActiveCampaign Privacy Policy |
| ipapi.co | IP-based geolocation for lead routing (city, region, country only — raw IP is not stored) | IP address (used for lookup only; only the resolved city/region/country is retained) | ipapi.co Privacy Policy |
| Google Analytics 4 | Website analytics and usage measurement | Anonymized page-view data, interaction events (no personally identifiable information) | Google Privacy Policy |
We do not sell your personal information to any third party.
Data Retention Policy
We retain personal information only as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial legislation.
| Data Type | Retention Period | Reason |
|---|---|---|
| Registration and contact form submissions (name, email, phone, company) | 24 months from last interaction | Active prospect follow-up and legitimate business interest |
| IP geolocation data (city, region, country) | 24 months from submission date | Lead routing and fraud prevention |
| Email marketing records (consent, opens, clicks) | Duration of contact relationship, plus 12 months after unsubscribe | Proof of consent and anti-spam compliance (CASL) |
| Website analytics (Google Analytics 4) | 14 months (Google’s default retention setting) | Performance and traffic measurement |
| Server error logs | 30 days | Security monitoring and debugging |
Your Rights
Under PIPEDA, you have the right to:
- Request access to the personal information we hold about you
- Request correction of inaccurate or incomplete information
- Withdraw consent for marketing communications at any time (use the unsubscribe link in any email)
- Request deletion of your personal information, subject to our legal obligations
To exercise any of these rights, contact us at hello@proppaylx.app. We will respond within 30 days.