Privacy Policy

Effective Date: July 30, 2026  •  Last Updated: July 30, 2026

1. Introduction

XUPPAH (“we,” “our,” or “us”) operates the Anti-Grind OS™ platform and related AI automation services designed for Ontario real estate professionals. We are committed to protecting your personal information in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you visit xuppah.com, use our platform, or interact with any of our AI-powered tools and services. By using our services, you acknowledge that you have read and understood this policy.

2. Who We Are

3. Information We Collect

We collect the following categories of personal information:

a) Information You Provide Directly

• Full name, email address, and phone number
• Business name and real estate license information
• Billing and payment information (processed securely by our third-party payment processors)
• Communications with our team, support agents, and AI systems
• Information submitted through forms, assessments, calculators, or live demos

b) Information Collected Automatically

• IP address and device identifiers
• Browser type and operating system
• Pages visited, time on page, and navigation paths
• Referral sources and click-through paths

c) Information from AI Interactions

• Conversations with Nicole (our AI receptionist) and other AI-powered tools
• Call recordings and transcriptions where permitted by applicable law and with appropriate consent
• Responses to AI Impact Assessments, ROI Calculators, and interactive demo sessions
• Appointment and scheduling data processed through our platform

4. How We Use Your Information

We use your personal information to:

• Provide, operate, maintain, and improve the Anti-Grind OS™ platform and related services
• Process payments and manage your subscription account
• Respond to inquiries and deliver customer and technical support
• Send transactional emails and account-related service notices
• Send marketing and promotional communications where you have provided express or implied consent under Canada’s Anti-Spam Legislation (CASL)
• Improve and refine AI models using anonymized and aggregated data
• Comply with applicable legal and regulatory obligations
• Enforce our Terms of Service and protect against fraud or misuse

5. Consent

Where required under PIPEDA and CASL, we obtain your consent before:

• Sending commercial electronic messages (email or SMS marketing)
• Collecting personal information beyond what is necessary to deliver the services you have requested
• Sharing your personal data with third parties for marketing purposes

You may withdraw your consent at any time by contacting us at [email protected] or by using the unsubscribe link included in any of our marketing communications. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

6. Sharing Your Information

We do not sell your personal information to third parties. We may share your information in the following limited circumstances:

• Service providers: Payment processors, cloud hosting providers, CRM platform vendors, and other operational partners, each bound by data processing agreements that restrict use of your data
• AI service providers: Third-party AI platforms that power our automation and conversation tools, under confidentiality and data processing obligations
• Legal authorities: When required by law, valid court order, or to protect the rights, property, or safety of XUPPAH, our clients, or the public
• Business successors: In the event of a merger, acquisition, or sale of business assets, with advance notice provided to you and subject to equivalent privacy protections

7. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and understand how visitors use our site. You may manage cookie preferences through your browser settings at any time.

We use the following types of cookies:

• Essential cookies: Required for core website functionality and security
• Analytics cookies: Used to understand how visitors navigate our site so we can improve it

We do not deploy advertising, retargeting, or behavioural tracking cookies without your explicit prior consent.

8. AI-Powered Services

The Anti-Grind OS™ platform includes AI-powered features, including but not limited to:

• Nicole — AI receptionist for lead response, qualification, and appointment booking
• Automated follow-up email and SMS sequences
• Conversation AI and voice automation tools
• AI Impact Assessments, ROI Calculators, and interactive prospect demos

Interactions with these AI features may be logged and stored in accordance with this Privacy Policy. AI-generated responses and outputs are provided for operational assistance only and do not constitute professional real estate, legal, financial, or compliance advice.

9. Data Retention

We retain your personal information for as long as is necessary to deliver our services, maintain our business records, and comply with applicable legal obligations. When your account is closed or your engagement with us ends, we will delete or anonymize your personal information within 90 days, unless a longer retention period is required or permitted by law.

10. Your Privacy Rights

Under PIPEDA and applicable Ontario privacy law, 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 certain uses of your personal information
• Request deletion of your personal data, subject to our legal retention obligations
• File a complaint with the Office of the Privacy Commissioner of Canada at www.priv.gc.ca

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days of receiving your request.

11. Data Security

We implement industry-standard security measures — including encryption in transit and at rest, role-based access controls, and regular security assessments — to protect your personal information from unauthorized access, disclosure, alteration, or destruction.

No method of data transmission or electronic storage is completely secure. While we take every reasonable precaution, we cannot guarantee absolute security. In the event of a data breach that poses a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by law.

12. Third-Party Links

Our website and platform may include links to third-party websites and services. We are not responsible for the privacy practices or content of those external sites. We encourage you to review the privacy policy of any third-party site you visit before submitting personal information.

13. Children’s Privacy

Our services are intended solely for adult real estate professionals. We do not knowingly collect or solicit personal information from individuals under the age of 18. If you believe we have inadvertently collected information from a minor, please contact us immediately at [email protected] and we will promptly delete it.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or applicable law. We will post the revised policy on this page with an updated effective date. For material changes, we will provide additional notice to active subscribers by email at least 14 days before the changes take effect. Your continued use of our services after that date constitutes acceptance of the updated policy.

15. Contact Our Privacy Officer

For privacy-related inquiries, to exercise your rights under PIPEDA, or to submit a complaint, please contact us: