Privacy Policy

This Privacy Policy explains how AI Canadian Solutions ("AICS", "we", "us") collects, uses, discloses, and protects personal information in connection with the website and investor portal at investorcoalition.aicanadiansolutions.ca (formerly siregsimpleinvestorcoalition.aicanadiansolutions.ca) (the "Platform"). We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Ontario law.

1. Information we collect

• Identity and contact information: name, email address, telephone number, city, and login credentials.
• Investment information: project/property, capital invested, wire/payment dates, and notes you provide.
• Documents and media you upload: agreements, offering materials, wire receipts, title documents, statements, correspondence, and video statements.
• Property details: the properties you enter under "My Investments", such as unit, address, purchase price, mortgage and fee details, tenant status and your plans for the property.
• Tenant information: if you provide a tenant's name or phone number, it is encrypted and is shared only with a property manager the coalition secures on owners' behalf. It is never included in packages for legal counsel.
• Survey answers: your answers to coalition surveys, including whether you intend to join a group action.
• Community content: posts, replies, reactions and upvotes in the investor forum, and records of moderation (including the text of removed posts and the reason for removal).
• Technical information: IP address, browser type, and activity logs necessary to operate and secure the Platform.

We may also receive your information from a registration form or response spreadsheet that you or another investor completed, or from a CSV list of existing investors provided to us.

2. Why we collect and use it

• to verify that you are an investor and to create and administer your account;
• to organize and store documents for assessment by any legal counsel and forensic accountants that may be retained, and by the coalition's organizers;
• to coordinate, fund, and pursue investor claims and related proceedings;
• to communicate with you about the coalition, including verification and invitation emails;
• to operate, secure, and improve the Platform; and
• to comply with legal obligations and respond to lawful requests.

3. Consent

We collect, use, and disclose personal information with your consent, which may be express (for example, the checkbox you accept when uploading documents, or the consent toggle for publishing a testimonial) or implied by your use of the Platform. You may withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice; withdrawing consent may mean you can no longer participate in the gated portal.

4. Disclosure to third parties

We disclose personal information only as described here:

• Legal counsel, forensic accountants and committee members that may be engaged, and the coalition's organizers — for the purposes described above;
• Service providers that host and operate the Platform, including cloud storage (Amazon Web Services S3, region ca-central-1), email delivery (SendGrid), data synchronization (Google), and approximate IP location lookups for visit statistics (ipwho.is / ip-api.com); these providers process information on our instructions;
• Professional advisers (auditors, insurers) as necessary;
• Courts, regulators, and law enforcement where required or permitted by law; and
• Public display — only where you have expressly consented (for example, a testimonial you mark as public and that is approved for publication).

Packages for legal counsel. When the coalition shares information with a law firm, it does so as a package containing members' contact details, property details, intake and survey answers, and uploaded documents with their upload record. Survey answers may determine which members are included (for example, only members who intend to join a group action). Packages are delivered only to the named lawyers through a secure, time-limited download that requires a one-time code sent to their own email address, and every view and download is recorded. Tenant names and phone numbers are never included.

We do not sell personal information.

5. Cross-border processing

Documents are stored in Canada (AWS ca-central-1). Some service providers (for example, email delivery and data synchronization) may process information in the United States or other jurisdictions, where it may be accessible to authorities under local law. By using the Platform you consent to such transfer, subject to our contracts with those providers.

6. Security

Specifically, and in plain terms:

• In transit. The entire Platform is served over HTTPS (TLS). Documents you upload travel encrypted from your browser to storage.
• At rest. Uploaded documents are not kept on the web server. They are written to Amazon S3 in the ca-central-1 (Canada) region and encrypted at rest by AWS using AES-256 server-side encryption.
• Not publicly reachable. The storage bucket is private. There is no public link to any document. Requesting a file's storage address directly, without authorisation, returns an error rather than the file.
• Short-lived access links. When you or an administrator opens or downloads a document, the Platform generates a signed link that expires within minutes and is tied to that single file. The link cannot be reused after it expires, and sharing it does not grant lasting access.
• Upload audit record. For each document we record the date and time of upload, the IP address it was uploaded from, the browser and device reported by your browser, and the moment you accepted the upload terms. This exists so a document's provenance can be evidenced later, and so unauthorised uploads can be identified.
• Access controls. Investor accounts are individually invited and password-protected. You can see only your own documents; administrators can see documents submitted to the coalition in order to review and organise them.

We also use reasonable administrative, technical, and physical safeguards, including restricted server access. No method of transmission or storage is completely secure, and we cannot guarantee absolute security — a determined attacker, a compromised device, or your own password being reused or shared can defeat any of the above. You are responsible for safeguarding your password and for the security of the device you sign in from.

7. Retention

We retain personal information for as long as necessary for the purposes described above and to comply with legal obligations. Where litigation is reasonably anticipated or commenced, we may place information under a legal hold and retain it until the matter and any appeal are finally concluded.

Forum posts removed by their author or by a moderator are kept, with the reason for removal, in a moderation log for accountability and dispute resolution. Upload records (date, time, IP address and device) are kept for as long as the related document. Visit statistics (see section 9) are deleted automatically after 13 months.

8. Your rights

Subject to applicable law, you may request access to your personal information, ask us to correct it, or withdraw consent to certain uses. To make a request, contact our privacy contact below. We may need to verify your identity before responding. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.

9. Cookies, sessions and visit statistics

The Platform uses cookies and session data to keep you logged in and to secure your session. The public website also uses Google Analytics, which sets cookies to measure visits (for example, pages viewed, approximate location and device type) so we can understand how the site is used; this information is processed by Google, which may process it outside Canada. We do not use advertising cookies and we do not sell data. You can block or delete cookies in your browser settings, or use Google's opt-out add-on.

Our own visit statistics. Separately from Google Analytics, the Platform keeps its own count of page visits, on the public website and in the investor portal, so we can see which pages are used and roughly where visitors are. For each visit we record:

• the page visited, and the date and time;
• the website you came from (its domain only), and whether you used a phone, tablet or computer;
• your approximate city, region and country, worked out from your IP address; and
• a scrambled visitor code made from your IP address and browser, which lets us count unique visitors. It cannot be turned back into your IP address, and we do not store your IP address in these records.

To work out the approximate location, your IP address is sent to an IP-location service (ipwho.is, or ip-api.com as a back-up), which may be located outside Canada. We keep only the city-level result, never a street address or precise location. If you are signed in to the investor portal, the visit is linked to your account.

On the homepage we count, in the same way, whether the "Welcome — who are you?" window was shown and which option was chosen (Owner / Investor, Tenant or Other) or whether it was closed. If you tick "Save my choice for a week", a small cookie remembers your choice for 7 days so the window is not shown again.

Visits by coalition administrators and automated programs (bots) are not counted. Only coalition administrators can see these statistics, which are shown as totals, and the records are deleted automatically after 13 months. These statistics are never used for advertising and are never sold or shared.

10. Children

The Platform is not directed to persons under 18, and we do not knowingly collect their personal information.

11. Changes

We may update this Policy; the "Last updated" date above will reflect any change.

12. Contact

Privacy contact: globalestatecorps@gmail.com.