Privacy Policy

Draft — pending final legal review. This page is a placeholder scaffold, not a final description of data-handling commitments, until a qualified privacy professional or legal counsel replaces every [PLACEHOLDER] below and signs off.

Last updated: July 24, 2026

1. Who we are

HBTUS TECHNOLOGY INC. ("we", "us", "our") operates the Ribbt real-estate CRM (the "Service"). This policy describes how we collect, use, and disclose personal information in the course of operating the Service. Privacy Officer contact: Dr. PEDROM NASIRI, [email protected].

2. Information we collect

We collect the following categories of information:

• Contact identifiers — name, email, phone, mailing address (entered by you or imported)
• Transaction data — property details, deal status, commission records
• Communication content — email bodies, SMS bodies, calendar event details
• Consent records — marketing-consent type, date, and source
• Authentication data — hashed password, session tokens, login timestamps
• OAuth tokens — for connected Google / Microsoft accounts, where applicable
• Billing identifiers — Stripe customer ID, subscription tier
• MLS credentials — your MLS board bearer token or client secret, stored encrypted, where you connect an MLS account

We collect only what's necessary to operate the Service for you.

3. How we use information

Personal information is used to provide the Service — client relationship management, sending communications you initiate, opt-in marketing campaigns to contacts who have given consent, property-search assistance (pulling MLS listing data for your own connected MLS account), billing and account management, security and fraud prevention, and compliance with applicable law.

4. Sub-processors and cross-border transfers

The Service relies on the following third-party sub-processors, each protected by TLS in transit:

Sub-processors located in the United States are subject to U.S. law (including the CLOUD Act), which may permit government access to information without notice to individuals. [PLACEHOLDER — province-specific cross-border transfer disclosures, if required.]

Google and Microsoft connected-account data. When you choose to connect a Google or Microsoft account, Ribbt accesses only your calendar, tasks, and contacts — and, where you connect email, your messages — to provide the calendar sync, task sync, contact import, and inbox features you enable. Ribbt’s use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. This data is used solely to provide those features, is stored encrypted and isolated per customer, is never sold, never used for advertising, and never used to train generalized AI models, and is not shared except as needed to provide the feature or as required by law. You can disconnect a connected account at any time.

5. AI / inference layer

AI features are opt-in and off by default. When you turn them on, inference runs on the OpenAI model we include (gpt-4o-mini) unless you supply your own key for a provider you connect instead (OpenAI, Anthropic, or Google). Prompt content sent to whichever provider is active — which may include personal information — is transmitted to that provider over TLS; see the sub-processor table in Section 4. AI access is technically blocked until it is explicitly enabled, and AI can never take an action on your records until an administrator opens the autonomy gate. Statistical reporting (source ROI, correlation, stalled-deal scoring) is computed in your own database and involves no AI provider.

6. Data retention

After a subscription is cancelled. Ninety days after a customer cancels, the personal information their workspace holds is permanently deleted: contact records are irreversibly stripped of every identifying detail (name, email, phone, address, notes, consent records, and the associated communication content), email and SMS message content and threads are deleted, and calendar events — including titles, descriptions, locations, and attendee lists — are deleted. This is irreversible and no archival copy is kept. Reactivating the subscription within the 90 days stops the deletion. See the Terms of Service (Section 7) for the categories that are deliberately retained past that window.

Individual records deleted during a subscription. A contact record deleted from within the Service is held as a recoverable soft-delete and then permanently erased once a configurable retention window has elapsed since the deletion; that purge does not run at all until a retention window has been explicitly configured for this deployment. [PLACEHOLDER — state the configured soft-delete retention window, and the retention that applies to consent, billing, and security-audit records.]

Inspection reports (active custody, not archive of record). A published inspection report and its photos are held only for as long as your subscription is active, plus a 90-day grace period after cancellation. If the subscription has not been reactivated by the end of that grace period, the report, its photos, and the underlying files are permanently deleted from the Service and cannot be recovered — Ribbt does not keep an archival copy on your behalf past that point. You are responsible for retaining your own copies of any report you need to keep longer; a one-click export (report + original photos, bundled) is available at any time before deletion.

7. Your rights

You may have the following rights regarding your personal information, subject to applicable law:

• Access — request a copy of the personal information we hold about you.
• Correction — request correction of inaccurate information.
• Erasure — request deletion of your personal information once it's no longer needed.
• Withdraw consent — opt out of marketing communications at any time (every campaign email includes a one-click unsubscribe link).

To exercise any of these rights, contact us at the details in Section 9. We respond to access, correction, and deletion requests within 30 days.

8. Security

We apply role- and row-level access controls — PostgreSQL Row-Level Security is enabled and force-enabled on every tenant table, and the application connects with a least-privilege database role that cannot bypass Row-Level Security even as a superuser could — encryption at rest for sensitive fields (attachments, connected-account credentials, and OAuth and AI/email-provider keys, AES-256-GCM), TLS in transit for all sub-processor connections, hashed passwords, cryptographically random session tokens that are invalidated on logout, and rate limiting on authentication endpoints. Access to customer data is limited to our Privacy Officer, Dr. PEDROM NASIRI, who is currently the only person at the company and the only individual with operational access to production systems; the Privacy Officer is also responsible for incident response. Customer data is backed up on a regular schedule.

9. Contact

Privacy questions, access requests, or complaints can be directed to Dr. PEDROM NASIRI at [email protected] or 13123 Bonaventure Drive S.E., Calgary, Alberta, T2J 7E9. See also Terms of Service.

10. Changes to this policy

We will post an updated version of this policy here when material changes are made, and notify existing accounts of significant changes by email.