Privacy Policy

Aktus Praxis Real Estate Appraisal Platform — Issued by Aktus Praxis Inc. — Effective: April 15, 2026 — Version 1.0

Deployment note: This policy applies to the Aktus Praxis platform software. When the platform is installed and operated on an appraiser's own machine, the appraiser is the data controller for all client and property information they enter. See Section 11 for the full appraiser responsibility statement.

1. Introduction and Scope

This Privacy Policy describes how Aktus Praxis Inc. (we, us, or our) collects, uses, discloses, retains, and protects personal information in connection with the Aktus Praxis Real Estate Appraisal Platform (the Platform).

The Platform is developed and owned by Aktus Real Estate Ltd. Software licences are issued by Aktus Praxis Inc. under authority granted by Aktus Real Estate Ltd.

This Policy applies to:

Licensed users of the Platform (appraisers, administrators, and firm staff)
Clients and property owners whose information is entered into the Platform in connection with real estate appraisal engagements
Any individual whose personal information is processed through the Platform

We are committed to complying with the Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c. 5, and applicable provincial privacy legislation.

2. Accountability & Privacy Officer

Aktus Praxis Inc. has designated a Privacy Officer responsible for our compliance with PIPEDA and this Policy. All privacy-related inquiries, access requests, correction requests, and complaints should be directed to:

Privacy Officer, Aktus Praxis Inc.
Email: privacy@aktuspraxis.ca
Mailing address: 3558 Hazel Grove, Regina, SK, S4V 2S7, Canada
Response time: We will acknowledge your request within five (5) business days and provide a substantive response within thirty (30) days, as required by PIPEDA.

3. Personal Information We Collect

3.1 Platform User Account Information

When a user account is created, the following information is stored in the Platform database on the licensee's machine:

Category	Fields
Account identifiers	Username, email address
Professional identity	Full name, company name, appraiser licence number
Contact information	Phone number
Authentication data	Password (hashed only — never stored in plaintext)
Session and audit data	IP address, browser user-agent, login timestamps, actions performed

3.2 Appraisal Job and Client Information

When appraisers create and manage appraisal jobs, client and property information is entered and stored locally on the licensee's machine. This includes client names, contact details, property addresses, and owner names. Property addresses are treated as indirect personal identifiers. The appraiser is the data controller for this information. See Section 11.

3.3 Technical and Operational Data

Server access logs: HTTP method, request path, IP address, and timestamp
Audit logs: user actions, associated IP address and user-agent string
Application version information: used for update checks only (see Section 6.3)

3.4 Information We Do Not Collect

Payment or financial information
Biometric data
Analytics or behavioural tracking data (no analytics platform is integrated)
Any data transmitted to Aktus Praxis servers — in local deployment, all data remains on the licensee's machine

4. Purposes for Collection and Use

We collect and use personal information only for purposes a reasonable person would consider appropriate, including:

Account management: Creating, authenticating, and administering user accounts
Appraisal workflow: Enabling appraisers to create, manage, and generate reports
Geocoding and mapping: Resolving property addresses to coordinates for mapping features (see Section 6.1)
Security and audit: Logging user actions and IP addresses to detect unauthorized access
Application maintenance: Checking for software updates using the version number only
Legal compliance: Meeting obligations under PIPEDA and applicable regulations

We do not use personal information for automated profiling, marketing, advertising, or any purpose inconsistent with professional appraisal services.

5. Consent

Express consent: Users consent to collection of account information upon accepting the EULA at account activation.
Implied consent: Client and property information entered by appraisers is collected with the implied consent of the appraiser, who is responsible for ensuring appropriate authority exists in connection with their professional engagement.
Legitimate purpose: Technical data such as IP addresses and audit logs are collected without additional consent where necessary for security and regulatory compliance, consistent with PIPEDA Principle 3.

You may withdraw consent at any time by contacting our Privacy Officer. Withdrawal may limit or terminate your ability to use the Platform.

6. Disclosure of Personal Information to Third Parties

We do not sell, rent, or trade personal information. The following third-party disclosures occur during normal Platform operations:

6.1 Geocoding Service

When a user initiates a mapping or geolocation function, the Platform transmits the relevant property address to an external geocoding API to obtain geographic coordinates. This constitutes a disclosure of personal information (property addresses are indirect identifiers) to a third-party service provider.

Purpose: Geographic coordinate lookup for mapping features
Data transmitted: Property address string
Frequency: Once per mapping operation initiated by a user
Mitigation under consideration: Local geocoding databases (e.g., GeoBase Canada) to eliminate external address transmission in a future release

6.2 Municipal GIS Endpoints

Zoning and land-use data is retrieved from municipal GIS servers. Property coordinates (derived from geocoding) are transmitted. No names, owner information, or contact details are transmitted.

6.3 Software Update Check (GitHub API)

The Platform performs a daily check for software updates by querying the GitHub API. The application version number is transmitted. No personal information is included.

6.4 Statistics Canada Data

Economic and demographic data from Statistics Canada is pre-loaded into the local database on a scheduled basis. No personal information is transmitted to or from Statistics Canada. All StatCan data consists of aggregate indicators that cannot be linked to any individual.

6.5 No Other Third-Party Sharing

The Platform does not integrate:

Analytics or web tracking services (e.g., Google Analytics)
Third-party error reporting services (e.g., Sentry, Rollbar)
Payment processors, advertising networks, or email marketing platforms

All AI-assisted features operate locally on the licensee's own infrastructure. No data is transmitted to any external AI or machine-learning service.

7. Retention and Disposal

Data Category	Retention Practice
User account data	Duration of active account, plus a reasonable period for audit and legal compliance
Appraisal job and client data	In accordance with applicable appraisal regulations and the licensee's own retention obligations
Application server logs	Rotating basis: up to five log files of 10 MB each (~50 MB total), automatically overwritten
IP addresses and user-agent strings	Subject to the same server log rotation schedule above

8. Safeguards

Password hashing: PBKDF2-SHA256 with 600,000 iterations (OWASP 2023 compliant). Passwords are never stored or logged in plaintext.
Session security: Cryptographically signed session cookies. Session cookies are strictly necessary and do not contain personal information in readable form.
CSRF protection: Implemented on all state-changing requests.
Sensitive data masking: Log output filters values associated with sensitive keys (password, token, secret, email, phone).
Audit logging: User actions are recorded to support accountability and detection of unauthorized access.
Access control: Role-based access restricts personal information access by user role.
Security headers: X-Content-Type-Options, X-Frame-Options, Content-Security-Policy, and Referrer-Policy applied on all responses.
Local AI processing: All AI-assisted features process data locally. No personal information is transmitted to external AI services.

9. Cookies

The Platform uses cookies solely for the following strictly necessary purposes:

Cookie	Purpose
Session cookie	Maintains your authenticated session. Required for the Platform to function. Deleted on logout or browser close.
CSRF token	Prevents cross-site request forgery attacks. Required for secure operation.

We do not use analytics cookies, advertising cookies, tracking pixels, or any third-party cookies. No consent banner is required because only strictly necessary cookies are used.

10. Your Privacy Rights

Under PIPEDA, individuals have the following rights:

10.1 Right of Access

You have the right to request access to the personal information we hold about you. Contact our Privacy Officer (Section 2). We will respond within thirty (30) days.

10.2 Right of Correction

You have the right to request correction of inaccurate personal information. Contact our Privacy Officer to request corrections to your account data.

10.3 Right to Request Deletion

You have the right to request deletion of your personal information, subject to legal and regulatory retention requirements. Contact our Privacy Officer. We will respond within thirty (30) days.

10.4 Right to File a Complaint

If you believe we have not handled your personal information in accordance with PIPEDA, contact our Privacy Officer first. If unsatisfied, you may file a complaint with:

Office of the Privacy Commissioner of Canada
30 Victoria Street, Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376 — www.priv.gc.ca

11. Appraiser Responsibilities as Data Controller

Important — Local Deployment: When the Platform is installed and operated on an appraiser's own machine or firm infrastructure, Aktus Praxis Inc. does not host, access, or control the appraisal data stored in that installation.

In a local deployment, the licensed appraiser or firm is the data controller under PIPEDA for all client and property information entered into the Platform. This includes:

Client names, contact details, and addresses
Subject property addresses and owner information
All personal information appearing in generated appraisal reports

As the data controller, the appraiser is responsible for:

Maintaining their own privacy policy covering client PII, as required by PIPEDA and applicable professional standards (including CUSPAP)
Obtaining appropriate consent from clients for the collection and use of their personal information
Securing the machine and database on which the Platform is installed
Managing backup, retention, and disposal of appraisal data in accordance with applicable regulations
Disclosing to their clients that property addresses may be transmitted to a third-party geocoding service when mapping features are used (see Section 6.1)

Aktus Praxis Inc. provides the Platform as a licensed software tool and does not act as a professional real estate appraisal firm. Responsibility for the substantive content of appraisal reports, including any privacy certifications, rests with the licensed appraiser who generates and signs the report.

11.1 Report Output and Copyright

Appraisal reports, valuations, narratives, and other professional work product generated by a licensed appraiser using this Platform are the intellectual property of that appraiser or their firm. Aktus Real Estate Ltd. and Aktus Praxis Inc. claim no ownership over report content created by licensees in the course of their professional practice.

11.2 Future Hosted Deployment

If the Platform is deployed in a hosted or cloud environment where Aktus Praxis Inc. operates the infrastructure, a separate Data Processing Agreement (DPA) will be required and this Privacy Policy will be updated accordingly. Hosted deployment terms will be communicated to licensees prior to any such transition.

12. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices, the Platform, or applicable law. When we make material changes, we will update the Effective Date, notify registered users through the Platform interface, and increment the version number.

13. Contact Us

Aktus Praxis Inc. — Privacy Officer
Email: privacy@aktuspraxis.ca
Mailing address: 3558 Hazel Grove, Regina, SK, S4V 2S7, Canada
Business hours: Monday to Friday, 9:00 AM – 5:00 PM (local time)

The Aktus Praxis Real Estate Appraisal Platform, including all software, templates, and documentation, is the intellectual property of Aktus Real Estate Ltd. The Platform is licensed — not sold — to users by Aktus Praxis Inc. pursuant to the applicable End User Licence Agreement. All rights reserved.

Aktus Praxis Inc. | Privacy Policy | Effective: April 15, 2026 | Version 1.0