Privacy Policy

Thanks for visiting Realstarter’s Privacy Policy (the “Policy”). We’ve updated our Policy as of April 15, 2024 to reflect certain changes in data privacy laws and our use of personal information.

You can read the updated Policy below. As always, thanks for using Realstarter, and please let us know if you have any questions or feedback.
Before you use or submit any personal information to Realstarter, please review this Policy carefully.
Definitions (these terms are not always capitalized throughout but these meanings apply)
• Backers. Backers are Realstarter’s users and others who pledge to bring projects to life.
• Project owners. Project owners are other parties who run projects on the Realstarter platform. Backers pledge to support various Project owner projects hoping to get a reward.
• Personal information. Any information that identifies you directly or indirectly in combination with other data about you. Personal information does not include information that is publicly available, de-identified, or aggregated.

Changes to this Policy
We may update this Policy from time to time as privacy laws or our practices change. We encourage you to review this Policy periodically. If you keep using Realstarter after a change, we will assume you accept the current version of the Policy. This Policy may be translated into another language for your convenience; in the event of a conflict between the English version and any translations, the English version shall control.

Who We Are
Realstarter, (together with Canadian E Market, and their parents, subsidiaries, affiliates, agents, representatives, consultants, employees, officers, and directors—collectively, “Realstarter,” “we,” or “us”) provides services that help people bring real estate projects to life (our “Services”). Our main service is a funding platform for real estate projects. We are a Technology company based in Winnipeg, Manitoba, Canada.

How this Policy Applies
This Policy describes the personal information we collect from you, how we use that personal information, and our reasons for doing so. It also explains when and how personal information may be shared and your rights and choices regarding the personal information you provide to us.
This Policy is incorporated into and part of Realstarter’s Terms of Use.

Personal Information We Collect
Realstarter collects personal information in several ways, primarily:
• When Project owners, and Backers provide personal information directly to us (such as when setting up an account);
• When we passively collect personal information from you (such as from your interaction with our website or mobile app); and
• From other parties (such as Realstarter’s trusted payment provider). To create an account on Realstarter and use our Services, we collect and process certain personal information. Depending on your use of our Services, this personal information may include:
• Personal information you provide by completing forms on Realstarter — for example, your name, email and postal addresses, telephone number, country of residence, login, and password details. We may ask for this information if you register as a user of the Services, subscribe to our newsletters, complete surveys, or submit content to Realstarter. You also may choose to login in to Realstarter using your existing Apple or Facebook account. When you do this, and in compliance with the permissions you grant, we may be able to access information about you from your Apple or Facebook account, such as the email address or profile picture associated with that account.
• Any personal information you include in your communications to Realstarter, such as when you ask for support, send us questions or comments, or report a problem with our Services.
• Personal information that you submit on or to Realstarter’s platform, such as comments, contributions to discussions, or messages to other users.
• Personal information you provide for identity verification purposes when launching a project, which can include your legal name, date of birth, and business name and Tax ID for business entities. In some cases, our payment processor will request that you provide us with a secure upload of an identity document (such as your passport, driver’s license, or other government-issued ID).
• Details of any transactions you make through the Services, such as who you paid, the date of payment, and what reward you were provided. Realstarter partners with Stripe for payment processing, and the payment information you submit is collected and used by Stripe in accordance with their privacy practices (read Stripe’s Privacy Policy). Realstarter only stores the last four digits of your credit card or bank account (as applicable), expiration date, and country, which we require for tax, regulatory, and security purposes. We do not store full payment card or bank account details.
• Information about your interactions with Realstarter, including use of our website and mobile app, such as your IP address, approximate location information, your device identifier, the type of device or browser you use, and your actions during your visit, including how you navigate our website or mobile app.
• Demographic information, such as your age, gender identity, sexual orientation, race, and ethnicity, when you choose to provide this information to help Realstarter equitably support all Project owners and represent a diverse population in our research. Typically, this information is only processed when you voluntarily choose to provide it to us. For example, Realstarter sends optional Project owner surveys that collect Project owner demographics, including things like gender identity and sexual orientation. The results of these demographic surveys are used by Realstarter to enhance the Project owner experience. The demographic information we collect includes personal information that may qualify as sensitive personal information under various privacy laws.
You may decline to provide us with your personal information. However, this can limit your ability to register for an account, create or back a project, or otherwise use our Services. You may review, update, or delete your account through your My account settings.

Cookies and Other Tracking Technologies
Realstarter collects data about website use through our own tracking technologies and tracking technologies provided by our vendors, such as those that help us with data analytics, marketing Realstarter projects, and content delivery. Some of this data may be considered personal information.
Realstarter commonly uses cookies and pixels. Cookies are small text files that may be saved by your internet browser when you visit a website. These text files then store information about your use of Realstarter’s Services that can be retrieved from your device. Pixels are snippets of code or tiny invisible images embedded in email and websites that help us learn how you interact with the content (for example, if you clicked on a link or an image).
Some tracking technology use is necessary for website functionality. These tracking technologies can also support website security, analytics, and an improved overall user experience. You may be able to use your browser settings to block tracking technologies, but blocking tracking technologies necessary for our website functionality may prevent you from using our Services.

How We Use Personal Information
We use the personal information we collect for various purposes, including to:
• register and service your account with us;
• send you transactional communications about your projects or pledges;
• provide customer service and respond to your requests for information;
• show you projects that may be of interest to you;
• send you marketing or promotional communications;
• analyze the use and functionality of our website and app;
• improve and develop the quality of your online experience, including through personalization;
• enhance the effectiveness of our Services;
• conduct research and analysis;
• effectively manage our business;
• prevent fraud and abuse; and
• monitor and improve the security of our Services.
We also use personal information we collect as reasonably necessary for our legal compliance, to maintain appropriate records for administrative purposes, to protect our rights and interests or those of others, to resolve disputes, to enforce our policies, to prevent harm, and for any other purposes permitted by applicable laws or for which you provide your consent.

How We Share Personal Information
There are certain circumstances in which Realstarter may share your personal information with others. Realstarter will seek to share the minimum amount of personal information necessary when your personal information is shared with others. The usual circumstances in which Realstarter may share your personal information are as follows:
• Realstarter may share your personal information with any other party based on your consent or instruction to do so.
• We may share your personal information with the vendors who perform services on our behalf, including recruiting, marketing, customer support, legal services, data storage, data analysis, and helping us detect and protect against fraud, illegal activities, malicious behaviors, security threats, and other misuses of our Services.
• We may share your personal information with current and future affiliated companies, including as part of a business transaction, such as corporate divestiture, merger, consolidation, acquisition, reorganization, or other disposition of all or any portion of our business or our affiliates, including in connection with a bankruptcy or similar proceeding.
• We may use and disclose any personal information as reasonably necessary to comply with law and legal requirements, cooperate with and respond to law enforcement requests, exercise or defend our legal rights or those of others, or as otherwise required by applicable law, court order, or governmental regulations.
• Any personal information we collect may be provided to our professional advisors, including accountants, auditors, consultants, and lawyers, when reasonably necessary for our professional advisors to perform services for us and give us appropriate advice.

Personal Information Shared Publicly on Realstarter
When you create an account, we create a basic profile page for you on Realstarter, containing your username, the date the account was created, and the number of projects you have backed or launched. By default, your profile is private and will not be publicly displayed.
You may delete your entire account by submitting a contact us form.
Project owners are asked to verify their identities before launching a project. Once this has been done, the Project owner’s Verified Name will be publicly displayed on their account profile and on any projects they launch.

Personal Information Shared with Project owners
Project owners are central to Realstarter’s Services as they provide the projects that drive our mission. Given that responsibility, Project owners are bound by this Policy.
Project owners never receive Backers’ credit card details or other payment information. Project owners also never ask for personal information at any point. Contact us at info@real-starter.ca if you receive a request for personal information from any product owner.
Project owners may also receive routine traffic analytics about their project pages and project marketing.
Realstarter reserves the right to take disciplinary action(s), including suspension, for any Project owner found to be in violation of any requirement or limitation set out in this Policy.

Links to Other Websites and Services
Realstarter’s website and app may include links to other websites or services whose privacy practices may differ from ours. When you follow a link to a website or service off of the Realstarter platform, the privacy policy and other disclosures for that website or service will govern their processing of your personal information.

Children’s Personal Information
Realstarter does not knowingly collect personal information from people under the age of 18. People under the age of 18 are not permitted to register for a Realstarter account or pledge to back projects. You must be at least 18 years old to run a project as a Project owner.
If you believe that someone under the age of 18 has provided us with personal information or that someone under 18 is a Project owner on a Realstarter project, please contact us at info@real-starter.ca. If we learn that we have received personal information from someone under the age of 18, we will delete such personal information in accordance with applicable law. We will take appropriate actions to remove projects run by people under the age of 18.

Privacy Rights and Choices
If at any time, you believe that your personal information has been used in violation of this Policy, you may report your concerns to us by emailing info@real-starter.ca

User Account Settings.
All Realstarter users can manage personal information in their My account settings. From your account, you can request a downloadable copy of your personal information from Realstarter. To correct or update the personal information you’ve provided to us, please log in and update your my account information. You may also delete your user account from within your account settings, or by emailing us at info@real-starter.ca We may retain personal information when required by law or as necessary for our business following an account deletion request.

Privacy Rights under Certain Laws.
Users in certain locations, such as the European Economic Area, United Kingdom, and California, are given certain privacy rights regarding their personal information. These rights include the right to know what personal information we process about you and to request access to, correction of, and deletion of your personal information. You also may have the right to ask for a portable copy of your personal information or to object to or ask that we restrict our processing of your personal information. If we rely on your consent for personal information processing, you may withdraw your consent at any time. Realstarter will not discriminate against any user for exercising privacy rights provided by applicable law.
If you would like further information regarding your legal rights under applicable data privacy law or would like to exercise any of them that are relevant to you, contact us at info@real-starter.ca. In your email, please include your full name, zip code or postal code, the email address at which you prefer to be contacted and, if different, the email address associated with your Realstarter account, and the privacy right(s) you are requesting, such as the deletion of information related to a particular transaction or the correction of specific information about you. Please monitor your incoming email correspondence in case we have follow-up questions regarding your privacy request.
Certain laws allow an authorized agent acting on your behalf to make privacy requests, which they may do by following the instructions above. If an authorized agent submits a request for you, we may ask you to verify your own identity or confirm the request directly with us.
Subject to appropriate verification of your identity, which may include asking you for additional information to match to information we have, Realstarter will honor the privacy rights provided to you by applicable law (such as the European Union’s General Data Protection Regulation if you are located in the European Economic Area). You can expect that Realstarter will respond to your privacy request within the required time period under applicable law, unless we reach out to explain that it will take us longer. If we cannot fulfill your privacy request in whole or in part, we will explain why. It is our policy not to disclose any information in response to a privacy request that may adversely affect the privacy of other persons unless legally required to do so.
If you have any questions about our response to your privacy request, please contact us at info@real-starter.ca. While we will always try to assist when you have concerns about the privacy of your personal information and appreciate an opportunity to do so, if you have concerns about how we manage your personal information or respond to your requests, you may be able to file a complaint with your local data protection authority or privacy regulator.

Our Communications
Realstarter wants to communicate with you only if you want to hear from us. We try to keep emails to a minimum, and you can unsubscribe from marketing or promotional communications at any time by selecting the “unsubscribe” link in any communication you receive. If you download the Realstarter app, you can manage the notifications you receive on your mobile device in your profile settings. Additionally, to improve our services we may contact you for market research purposes. You always have the choice about whether to take part in our market research.
Even if you unsubscribe from marketing communications, Realstarter and our Project owners will still be able to send you communications relating to your transactions and rewards, such as successful projects you have backed. This helps ensure we can provide you with updates on your rewards. We’ll also be able to send you service-related announcements when it’s necessary to do so.

Personal Information Retention
In general, we keep personal information as necessary to provide you with our Services. We will typically retain your personal information as long as your account is active and for a reasonable period of time afterward. We will retain and use personal information as permitted by law, as necessary for any purposes explained in this Policy and any reasonably compatible purposes, and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and protect Realstarter’s legal rights and those of our users. Where your personal information is used for more than one purpose, we will retain it until the last retention period is met.
In determining our retention periods, we consider factors such as our legal and contractual obligations, as well as the amount, nature, and sensitivity of the personal information, the purposes for which we process the personal information, and the potential risk of harm that may result from unauthorized processing of the personal information.

Personal Information Security
The security of your personal data is important to us. We look to good industry practices to protect the data we collect and maintain, including using Transport Layer Security (TLS) to encrypt information as it travels over the internet. No method of transmission over the internet or electronic storage is completely secure, so Realstarter cannot guarantee the security of your personal information. Your account information is protected by a password, which you should choose carefully and keep secure. We encourage all users to enable two-factor authentication in my account settings to further protect their account. We also encourage the responsible disclosure of vulnerabilities of our Services by emailing info@real-starter.ca, and we will invite valid disclosures to our bug bounty program.

Notice to Our Users from the United States
Over the past several years, more than a dozen states have passed privacy laws to protect consumers in those states. We recognize the privacy rights of consumers residing in any state with an active consumer privacy law that is applicable to Realstarter. If you are a resident of a state with an active consumer privacy law, and you want to ask for additional information about your rights, you may contact us at info@real-starter.ca.
No Sales of Personal Information and Targeted Advertising State privacy laws may permit consumers to opt out of the sale of personal information, including when that personal information is provided to others in exchange for non-monetary value or to facilitate targeted advertising. Realstarter does not engage in these activities as they are defined in the state consumer privacy laws applicable to Realstarter.

Additional Information for California Residents
This information supplements other parts of this Policy and provides additional information to California residents in accordance with the requirements of the California Consumer Privacy Act. Here we provide additional information about our personal information processing practices in the previous 12 months and our current personal information collection practices. Please read this information in conjunction with the other portions of our Policy. For instance, we have described the personal information we collect, the sources from which we collect personal information, and our purposes for that collection at the beginning of this Policy. We have also explained how we disclose personal information to others and how you can exercise your privacy rights in other portions of our Policy.
California Personal Information We Collect
Throughout this Policy, we discuss the specific pieces of personal information we collect from and about our users. Note that the personal information we collect about you may vary depending on the nature of your interactions with us and may include all or some of the examples listed below or additional types of personal information in the categories we identify:
• Identifiers and Non-Public Personal Information, such as your full name, contact information, account username, IP address, or government-issued identification.
• Commercial Information, such as the history of projects you created or backed and rewards obtained from successful projects.
• Inferences, such as information about your project preferences and projects you may be likely to create or back.
• Internet Activity Information, such as what you search for on our website or app and other information about how you interact with our website or app.
• Geolocation, including approximate location inferred from your IP address.
• Audio and Visual Information, such as recorded customer service interactions and photos or videos that you might submit.
• Professional Information, such as a Project owner’s business name and business tax identification number.
• Protected Characteristics, when you choose to provide them, such as race or ethnicity, gender or gender identity, sexual orientation, or age (if you are over 40).
We may disclose any of these categories of personal information to our service providers, Project owners, and others as described in the “How We Share Personal Information” and “Personal Information Shared with Project owners ” sections above.
Realstarter may process sensitive personal information such as driver’s license number, passport number, information about racial or ethnic origin, information about sexual orientation, and contents of messages between users of Realstarter. We do not use or disclose sensitive personal information for purposes that would give rise to the right to limit the use and disclosure of this data.

California Privacy Rights
In addition to the rights described in the “Privacy Rights and Choices” section above, California residents may ask us for information about our processing of their personal information, including the categories and sources of personal information, our purposes for processing personal information, and how we disclose personal information to others.
You, or an authorized agent acting on your behalf, may submit any California privacy rights requests to us by emailing info@real-starter.ca. Please include your full name, zip code, the email address at which you prefer to be contacted and, if different, the email address associated with your Realstarter account, and the privacy right(s) you are requesting.

California Notice of Financial Incentives
Realstarter may choose to offer financial incentives to our users from time to time. If we offer financial incentives to California residents that involve certain uses of personal information, we will provide you with a separate notice regarding the financial incentive when we offer it. This notice will describe the financial incentive offered, including any material terms, how you can participate or withdraw from participation, and information about how any price or service difference offered to you is related to the value of your personal information processed as part of the incentive.

California Shine the Light Law
California’s “Shine the Light” law gives Californians the right to request information from us about how we share personal information with other parties for their direct marketing purposes. Realstarter does not share your personal information for this purpose.

Notice to All Users
Realstarter, is the data controller responsible for personal information we collect through our website and app. Our Data Protection Officer can be contacted at info@real-starter.ca.

International Personal Information Transfers
Realstarter is based in Canada. If you are using our website or app outside Canada, please be aware that your personal information is being sent to and processed in Canada. Canada has its own laws governing privacy and government access to personal information that we need to comply with. The rules that protect your personal information under Canadian law are likely different than in your home country. By providing us with your information, you acknowledge and permit our processing of your personal information in Canada.

Our Legal Bases for Processing Personal Information
When applicable under foreign data protection laws, such as the European Union’s General Data Protection Regulation, Realstarter relies on the following legal bases for processing personal information:
• Obligations to You. We use your personal information to give you information about the projects you create or back, to enable Project owners to launch and display their projects, and to allow Backers to find and make pledges to them and obtain rewards.
• Our Legal Requirements. Sometimes laws, regulations, and other binding legal obligations say we need to collect and use your personal information. For example, tax laws require us to retain records of pledges and payments made through our Services.
• Our Legitimate Interests. This is a legal term in data protection law that means that Realstarter has a good and fair reason to use your personal information, and we do so in ways that are balanced with your interests and rights. For example, we might rely on our legitimate interests when we process personal information to protect the security and integrity of our website or app or when we personalize information users see on Realstarter to help our users find the information they want quickly. When we rely on our legitimate interests, we take into account the effects that these actions might have on you. If you have questions about our decisions regarding our legitimate interests, you may contact us.
• Your Consent. We may ask for your consent for certain personal information processing. For example, we may rely on your consent to use non-essential cookies or to provide you with marketing communications. When you consent, you may withdraw your consent at any time by contacting us at info@real-starter.ca.
In certain countries, you may have the right to file a complaint with a data protection authority if you believe our use of your personal information violates your rights under applicable data protection or privacy law. Although Realstarter has not independently verified its accuracy, a list of data protection authorities is maintained by the International Association of Privacy Professionals.

Contact Us
To contact our Data Protection Officer with questions about this Policy wherever you are based, whether in Canada or internationally, please email info@real-starter.ca. To make privacy requests, including accessing or deleting your data or account, email us as well.


You can contact us in writing at:
Realstarter, a Canadian E Market Company
1745 Pembina Hwy,
Winnipeg, MB R3T 2G6
Canada