Privacy Policy

01Who we are and what this covers

This Privacy Policy explains how the federal (Canada) corporation that operates in Québec under the registered business name Levercomm (Levercomm, we) collects, uses, discloses and protects personal information when you use our website and software (the Service). Levercomm handles personal information in line with applicable Canadian and Québec privacy laws, including Québec's Act respecting the protection of personal information in the private sector, as amended by Law 25.

02Person in charge of privacy

You can contact the privacy officer about any question in this policy, to exercise your rights or to make a complaint.

03Personal information we collect

From you, when you use the Service

• Account information: name, work email, brokerage or firm name, sign-in details.
• Licence information (broker plans): your name, province and brokerage name (if given), used to confirm your licence in the background against your province's public registry; your licence number only if we ask for it in the app because we could not match it; and the result of that check.
• Billing information: plan, billing history and the last digits of your card. Card numbers are handled by our payment provider, Stripe, and are never kept by Levercomm.
• Communications: messages you send us and your email preferences, including CASL consent.

Documents and deal files in your Google Drive

Deal documents, client documents (for example a net worth statement, a signed mandate, rent rolls or financial statements, including those your clients send through intake links) and the packages Levercomm builds are kept in your own Google Drive. They may contain personal and financial information. Levercomm reads them, with your permission, to do the work you ask for. It does not keep copies of your Drive files.

On our website

If you fill in a form on our website, for example to ask a question or to be contacted, we receive what you enter, such as your name, email, firm and message.

Automatically

Technical information such as device, browser, IP address and pages used, and cookies as described in our Cookie Policy.

04Why we use it

• to provide the Service: reading the documents in your Drive to run the underwriting, the Levercomm Rating, lender matching, packages, emails and campaigns you send;
• to answer website form requests and questions you send us;
• to manage your account, trial, subscription and billing;
• to send service messages and, with your consent, product updates and the Market Desk forecast;
• to secure the Service, prevent abuse and meet legal obligations;
• to understand use of the Service and improve it.

We collect only what we need for these purposes and do not use personal information for other purposes without consent, unless the law allows it.

05Consent

We rely on your consent, which may be express or implied depending on the sensitivity of the information. You may withdraw consent at any time, subject to legal or contractual limits; we will explain the consequences, for example that some features may stop working. Marketing emails are sent only with express consent and include an unsubscribe link.

Brokers: when you collect a client's information or put it in your Drive for Levercomm to read, you are responsible for obtaining that client's consent to its collection, use in Levercomm and disclosure to lenders you choose.

06Brokers and their clients

For client information that brokers collect, the broker decides why and how it is used, and keeps it in the broker's own Google Drive. Levercomm reads it on the broker's behalf only to provide the Service. Clients who want to access, correct or delete their information should first contact their broker; we will help the broker respond.

07Where your information is kept

Some of our service providers, such as Google, Anthropic and Stripe, process information outside Québec and Canada, including in the United States, where it may be accessible to authorities under local law. Before communicating personal information outside Québec, we assess whether it will receive adequate protection, as Québec law requires.

08Google Drive

When you connect Google Drive, Levercomm accesses the folders and files you choose so it can do the work you ask for, such as reading documents for underwriting or saving a package to your Drive. Your files remain in your Drive under your Google account; Levercomm does not copy them to its own systems. You can view, change or delete them in Drive yourself at any time, and disconnect Google Drive at any time from your account or your Google settings. Google's own privacy terms apply to your Google account.

09Service providers and disclosure

We share personal information only with service providers that help us run the Service, under contracts that require them to protect it and use it only for us. These include:

Information you choose to send to lenders, such as packages, is disclosed by you. We do not sell personal information. We may disclose information where required by law or in connection with a business transaction, under the conditions the law sets.

10Automated processing

The Service uses automated analysis to produce underwriting figures, the Levercomm Rating and lender fit rankings. These outputs support brokers' and lenders' own decisions; Levercomm does not make lending decisions. Where a decision about a person is based exclusively on automated processing, Québec law gives that person the right to be informed, to know the main factors and to have the decision reviewed by a person. Contact the privacy officer to exercise these rights.

11Retention and deletion

We keep account details until the account is deleted. When you delete your account, we erase them from our systems, and backup copies are overwritten within 30 days, except where we must keep some information longer by law (for example billing records for tax purposes). Website form messages are kept only as long as needed to answer you and for the purposes above.

Files in your own Google Drive are yours: deleting your Levercomm account does not delete them, and you can delete them yourself in Drive at any time.

12Safeguards

We use administrative, technical and physical safeguards appropriate to the sensitivity of the information. No system is perfectly secure. If a confidentiality incident presents a risk of serious injury, we will notify the affected people and the competent privacy authorities, including the Commission d'accès à l'information for Québec residents, and keep a register of incidents, as applicable law requires.

13Your rights

Subject to the law, you may:

• access the personal information we hold about you and ask how it was used and disclosed;
• correct information that is inaccurate or incomplete;
• withdraw consent;
• ask that information be deleted, or that its dissemination stop or a link be de-indexed where Québec law provides it;
• receive computerised personal information you provided in a structured, commonly used technological format (data portability, Québec).

See Requests about your information below for how to make a request.

14Requests about your information

To access, correct or delete your personal information, withdraw consent or ask for a copy of it:

1. Email admin@levercomm.com with the subject “Privacy request”. Say what you would like and, if you have an account, write from the email on it.
2. Identity check. Before we act, we confirm that the request comes from you, for example by replying to the email on your account. We ask only for what we need to confirm it.
3. Our answer within 30 days of receiving your request. If we cannot do all of what you ask, we tell you why and how to complain.

Files in your own Google Drive are under your control: you can view, correct or delete them yourself at any time, without asking us. Clients of a broker should first contact their broker about documents the broker keeps.

Requests are handled by the Privacy officer, Levercomm If you are not satisfied with our answer, you can complain to the Commission d'accès à l'information du Québec or the Office of the Privacy Commissioner of Canada.

15Cookies

We use cookies and similar technologies as described in our Cookie Policy. Optional cookies are off until you turn them on in Cookie preferences.

16Minors

The Service is for businesses and is not directed at minors. We do not knowingly collect personal information from minors.

17Changes to this policy

We will post updates here and give notice of material changes by email or in the Service before they take effect.