1.1 Who We Are. Creative Property Management Software Inc. (the "Company," "we") operates the property management platform at www.creativepropertymanagement.ca and its mobile applications (the "Services"). This policy explains how we handle personal information, cookies, data destruction, anonymized analytics, and data portability, in compliance with the Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial regulations.
1.2 Roles. Subscribers (landlords and property managers) are the sole Data Controllers of the Tenant Data they input; the Company processes that data on their instructions, as set out in the Terms of Service. This policy governs the Company's own practices as operator of the platform.
2.1 Classification of Cookies. The Site uses cookies in three distinct tiers:
| Tier | Category | Description | Consent Basis |
|---|---|---|---|
| (a) | Strictly Necessary Cookies | Required for secure log-ins and session authentication, Stripe payment routing, and BoldSign e-signature authentication. Cannot be disabled without breaking core functionality. | Always active |
| (b) | Performance Cookies | Measure how visitors use the Site (page load times, error rates, aggregate navigation patterns) solely to improve performance. | Opt-in required |
| (c) | Functional Cookies | Remember preferences such as language, dashboard layout, and display options for a personalized experience. | Opt-in required |
A detailed inventory of specific cookies, providers, purposes, and retention periods is maintained on the cookie preferences page.
2.2 Explicit Consent. Non-essential tracking cookies activate only if you click "Accept All" on the cookie banner. Until then, only Strictly Necessary Cookies operate. You have the absolute right to modify, withdraw, or re-grant your tracking preferences at any time through the cookie preference centre in your account dashboard; changes take effect immediately, and withdrawing consent is as easy as giving it. The Company retains timestamped records of consent choices for PIPEDA accountability.
2.3 No Tracking of Sensitive Data, Operational Guarantee. Cookies, web beacons, and similar technologies will never be used to track, store, capture, or profile highly sensitive applicant inputs, including Social Insurance Numbers (SINs), uploaded tenant identity document scans, banking credentials, or tenant screening responses. Sensitive entry fields and upload workflows are technically segregated from all analytics and tracking scripts.
3.1 Thirty (30) Day Grace Period. Upon account termination (by cancellation, in-app deletion request, or Company termination), all tenant personal information in the account, including bank account data, SINs, and photo ID uploads, enters a thirty (30) calendar day grace period, during which the account may be reactivated or a data portability export completed under Section 5.
3.2 Permanent Destruction on Day 31. On the thirty-first (31st) day, the platform permanently and irreversibly deletes or cryptographically overwrites the data across production databases and backup rotation cycles, in accordance with PIPEDA compliance guidelines, so that it cannot be recovered, reconstructed, or restored by anyone.
3.3 CRA Retention Exemption. Transactional billing records and financial ledgers are exempt from the destruction timeline and are retained for seven (7) years to satisfy Canada Revenue Agency requirements under the Income Tax Act and Excise Tax Act. Retained records are limited to what tax compliance requires, stored securely with restricted access, and destroyed when the statutory period expires.
3.4 No Post-Destruction Recovery. After the Day-31 destruction event, the Company cannot retrieve deleted data and bears no liability for its unavailability.
4.1 Complete De-Identification. The platform completely strips, scrubs, and permanently de-identifies all personal, individual, and corporate markers from raw system entries before compiling broad, aggregated data sets, using irreversible anonymization techniques (identifier suppression, generalization, aggregation thresholds).
4.2 Warranty. This processing is strictly mathematical and statistical: aggregated data sets never contain or track individual names, phone numbers, emails, banking information, or SINs, and cannot be reverse-engineered to identify any single landlord or tenant under the serious-possibility-of-identification standard in Canadian privacy guidance.
4.3 Commercial Rights. The Company maintains the absolute, perpetual, royalty-free right to utilize, monetize, license, and publish these anonymized data sets as macro-market reports, industry indices, average regional leasing metrics, and commercial analytics or industry insight reports. Because the data is fully anonymized, it is not personal information and its use does not require individual consent under PIPEDA. Nothing in this Section authorizes disclosure of identifiable personal information.
5.1 Export Right. Active subscribers may request and download a standard, machine-readable export of their proprietary operational data, lease templates, uploaded rental listings, and payment histories, directly through their account settings panel, in formats such as CSV, JSON, or PDF.
5.2 Sensitive Data Exclusion. To prevent mass identity theft risks outside the platform's secure Ontario AWS infrastructure, tenant background screening profiles, physical government ID uploads, and SINs are excluded from standard bulk exports. These remain viewable only within the secure platform during an active subscription. Individuals retain their PIPEDA right to access their own personal information through a verified individual access request fulfilled via secure channels.
5.3 Thirty (30) Day Post-Cancellation Window. Upon formal account cancellation, subscribers have a strict maximum of thirty (30) calendar days to execute their data portability export. After the window expires, the database automatically initiates the permanent, irreversible PIPEDA purging cycle described in Section 3, and the data cannot be recovered or exported. Subscribers are solely responsible for completing exports in time.
6.1 Processor Summary. The platform engages the following third-party processors, each limited to its stated function:
| Processor | Function | Data Handling Commitments |
|---|---|---|
| Stripe | Payment processing | Payments governed by Stripe's own agreements; the platform never holds funds. |
| BoldSign | Electronic signatures | Audit trail data (IP address, email verification metrics, timestamps) collected for legal enforceability. |
| Pusher | Real-time messaging and notifications | Strict transit pipeline; payloads encrypted in transit; contractually barred from storing, profiling, scraping, or repurposing data; no SINs, banking credentials, or ID images transmitted. |
| AWS (Canada) | Hosting infrastructure | Data hosted in secure Ontario AWS infrastructure. |
| IT support vendors | Technical support and maintenance | Bound by a Master DPA/NDA requiring background checks, PIPEDA-equivalent handling, VDI-only access, and a total ban on local storage, downloads, or screenshots of tenant data. |
7.1 Access and Correction. Individuals may request access to or correction of their personal information held by the Company by contacting the privacy officer at the address published on the Platform. The Company responds within the timelines required by PIPEDA.
7.2 Complaints. Concerns may be raised with the Company's privacy officer and, if unresolved, with the Office of the Privacy Commissioner of Canada.
7.3 Updates. Material changes to this policy will be posted on the Platform with reasonable advance notice.